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...
Withdrawal of exemption granted u/s 10(23C)(vi) - where the ld. CIT(E) has delegated his powers to any other authority to issue show cause notice and it is based on the satisfaction of that other authority and not of ld. CIT(E), it won’t satisfy the mandatory condition - But, in this case, condition of satisfaction of CIT(E) satisfied.
Withdrawal of exemption granted u/s 10(23C)(vi) - where the ld. CIT(E) has delegated his powers to any other authority to issue show cause notice and it is based on the satisfaction of that other authority and not of ld. CIT(E), it won’t satisfy the mandatory condition - But, in this case, condition of satisfaction of CIT(E) satisfied.
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