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...
Estimation of profit on undisclosed turnover - Addition @50% and granting relief @50% - assessment u/s 153A after search and seizure proceedings - Reliance of the statements u/s 132(4) of the assessee and third parties - retracted statements - Revenue failed to prove its case - entire additions deleted.
Estimation of profit on undisclosed turnover - Addition @50% and granting relief @50% - assessment u/s 153A after search and seizure proceedings - Reliance of the statements u/s 132(4) of the assessee and third parties - retracted statements - Revenue failed to prove its case - entire additions deleted.
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