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...
Penalty u/s 158BFA(2) - no willful default - additions made were only due to the difference in estimate - It is never the case of the Revenue that the undisclosed income was on account of any transaction, which was out of books but, the entire case arose out of valuation of the gold jewellery and the diamonds - no penalty
Penalty u/s 158BFA(2) - no willful default - additions made were only due to the difference in estimate - It is never the case of the Revenue that the undisclosed income was on account of any transaction, which was out of books but, the entire case arose out of valuation of the gold jewellery and the diamonds - no penalty
Note: It is a system-generated summary and is for quick reference only.
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