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...
In the absence of element of mens area, the appellant's conduct cannot be construed to fall within the five elements as required for invoking the extended time proviso - the charges of willful suppression or mis-statement of facts cannot be invoked
In the absence of element of mens area, the appellant's conduct cannot be construed to fall within the five elements as required for invoking the extended time proviso - the charges of willful suppression or mis-statement of facts cannot be invoked
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