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 221 - non payment of admitted tax - financial stringency is considered to be good and sufficient cause for sufficiency of reason for not levying penalty u/s 221(1) - when AO has not controvert the assessee’s reasons regarding paucity of funds then assessee could not be considered as willful defaulter - no penalty
Penalty u/s 221 - non payment of admitted tax - financial stringency is considered to be good and sufficient cause for sufficiency of reason for not levying penalty u/s 221(1) - when AO has not controvert the assessee’s reasons regarding paucity of funds then assessee could not be considered as willful defaulter - no penalty
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