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 of capital loss on account of capital reduction scheme - Extinguishment of rights in shares - definition of ‘transfer’ u/s 2(47) - Loss arising to the assessee for cancellation of its shares in CHIPL pursuant to reduction of capital should be allowed as long term capital loss eligible to be carried forward to subsequent years.
Disallowance of capital loss on account of capital reduction scheme - Extinguishment of rights in shares - definition of ‘transfer’ u/s 2(47) - Loss arising to the assessee for cancellation of its shares in CHIPL pursuant to reduction of capital should be allowed as long term capital loss eligible to be carried forward to subsequent years.
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