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...
Levy of penalty u/s 271AAA - Addition u/s 69A post search - assessee’s argument that the assessee’s explanation has not been found to be false and, therefore, penalty is not sustainable is not acceptable.
Levy of penalty u/s 271AAA - Addition u/s 69A post search - assessee’s argument that the assessee’s explanation has not been found to be false and, therefore, penalty is not sustainable is not acceptable.
Note: It is a system-generated summary and is for quick reference only.