Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Addition u/s 68 - share capital account received from Director by way of two cheques who was produced before AO alongwith their copy of account, balance-sheet income-tax return and even they are assessed in the same jurisdiction - order passed without dealing with all these details, before terming the amount to be non-genuine and making addition is not sustainable
Addition u/s 68 - share capital account received from Director by way of two cheques who was produced before AO alongwith their copy of account, balance-sheet income-tax return and even they are assessed in the same jurisdiction - order passed without dealing with all these details, before terming the amount to be non-genuine and making addition is not sustainable
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