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...
Additional ground - Claim of expenditure incurred on abundant project - assessee could not inadvertently make the aforesaid claim in the return of income - The words 'could not have been raised' must be construed liberally and not strictly. There may be several factors justifying the raising of a new plea in an appeal and each case must be considered on its own facts.
Additional ground - Claim of expenditure incurred on abundant project - assessee could not inadvertently make the aforesaid claim in the return of income - The words 'could not have been raised' must be construed liberally and not strictly. There may be several factors justifying the raising of a new plea in an appeal and each case must be considered on its own facts.
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