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...
Deduction u/s 80IB(10) - there could be no presumption that surrendered amount would represent business income unless and until assessees satisfies the authorities below that assessees have complied with the conditions of Section 80IB(10) while earning the impugned undisclosed income - Since assessee failed to prove through any evidence or material on record, same will be income from other sources - no deduction
Deduction u/s 80IB(10) - there could be no presumption that surrendered amount would represent business income unless and until assessees satisfies the authorities below that assessees have complied with the conditions of Section 80IB(10) while earning the impugned undisclosed income - Since assessee failed to prove through any evidence or material on record, same will be income from other sources - no deduction
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