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 a penalty u/s 271G - default of non-submission of documents within stipulated period as required u/s 92D(3) - Though there is a delay on the part of the assessee to file the requisite documents but ultimately documents have been filed and assessment has been framed and moreover no malafide on the part of the assessee not to comply with the provisions - Penalty deleted.
Levy a penalty u/s 271G - default of non-submission of documents within stipulated period as required u/s 92D(3) - Though there is a delay on the part of the assessee to file the requisite documents but ultimately documents have been filed and assessment has been framed and moreover no malafide on the part of the assessee not to comply with the provisions - Penalty deleted.
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