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 40(a)(ia) - non- deduction of TDS on provision for expenses - no bills and invoices were raised by the creditors and no liability of payment arose - the assessee is under no obligation to make payment and no TDS is deducted - Additions deleted.
Disallowance u/s 40(a)(ia) - non- deduction of TDS on provision for expenses - no bills and invoices were raised by the creditors and no liability of payment arose - the assessee is under no obligation to make payment and no TDS is deducted - Additions deleted.
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