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...
Penalty imposed u/s 271G - failure to furnish the information/documents required u/s 92D(1) r/w rule 10D - when the TPO has accepted the benchmarking of the assessee, the imposition of penalty under section 271G of the Act is unsustainable
Penalty imposed u/s 271G - failure to furnish the information/documents required u/s 92D(1) r/w rule 10D - when the TPO has accepted the benchmarking of the assessee, the imposition of penalty under section 271G of the Act is unsustainable
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