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 271(1)(c) - survey team did not make further enquiries nor was it established that these represented any other income - the amount disclosed during the survey was duly included in the original return of income filed after the date of survey hence there is no difference as such in the return of income and assessed income - no penalty
Penalty u/s 271(1)(c) - survey team did not make further enquiries nor was it established that these represented any other income - the amount disclosed during the survey was duly included in the original return of income filed after the date of survey hence there is no difference as such in the return of income and assessed income - no penalty
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