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...
Imposition of penalty and interest - Failure to discharge Service Tax - proper records of the receipt of sales commission by cheque were maitained, duly disclosed in the Income Tax record. Thus, there is no case of deliberate defiance of law or contumacious conduct as mis-statement of facts, and penalty set aside - AT
Imposition of penalty and interest - Failure to discharge Service Tax - proper records of the receipt of sales commission by cheque were maitained, duly disclosed in the Income Tax record. Thus, there is no case of deliberate defiance of law or contumacious conduct as mis-statement of facts, and penalty set aside - AT
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