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...
Merely because additions made by the AO have been partially upheld by the CIT (A), would not confer the ground to initiate proceedings u/s 271(1)(c) of the Act of imposition of penalty, unless it is found that there is concealment of material facts, or furnishing of inaccurate particulars.
Merely because additions made by the AO have been partially upheld by the CIT (A), would not confer the ground to initiate proceedings u/s 271(1)(c) of the Act of imposition of penalty, unless it is found that there is concealment of material facts, or furnishing of inaccurate particulars.
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