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...
Addition u/s 68 - LTCG on sale of penny stock - considering the vortex of evidences, the assessee has successfully discharged the onus cast upon him by provisions of section 68 - discharge of onus u/s 68 is purely a question of fact and therefore the judicial decisions relied upon by the DR would do no good on the peculiar plethora of evidences in respect of the facts of the case in hand - no addition
Addition u/s 68 - LTCG on sale of penny stock - considering the vortex of evidences, the assessee has successfully discharged the onus cast upon him by provisions of section 68 - discharge of onus u/s 68 is purely a question of fact and therefore the judicial decisions relied upon by the DR would do no good on the peculiar plethora of evidences in respect of the facts of the case in hand - no addition
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