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...
Levy of fee u/s 234E - delay in furnishing TDS statements / returns - Challenging the vires of Section 234E - Revenue is right in contending that Section 234 (E) of the Act is not a penalty. Penalty is levied under Section 271 (H) and is not automatic. - Since the levy is constitutional, the challenge to the demand notices also fail - HC
Levy of fee u/s 234E - delay in furnishing TDS statements / returns - Challenging the vires of Section 234E - Revenue is right in contending that Section 234 (E) of the Act is not a penalty. Penalty is levied under Section 271 (H) and is not automatic. - Since the levy is constitutional, the challenge to the demand notices also fail - HC
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