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...
Disallowance u/s 40A(3) - cash payments of expenditures - poor creditability in the market - genuineness of such expenditure is not in dispute - AO directed to sustain disallowance u/s 40A(3) to the extent of 5% of the alleged amount.AO to sustain disallowance u/s 40A(3) to the extent of 5% of the alleged amount.
Disallowance u/s 40A(3) - cash payments of expenditures - poor creditability in the market - genuineness of such expenditure is not in dispute - AO directed to sustain disallowance u/s 40A(3) to the extent of 5% of the alleged amount.AO to sustain disallowance u/s 40A(3) to the extent of 5% of the alleged amount.
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