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...
Addition u/s 40A - purchase by cash exceeding ₹ 20,000/- on various dates in one bill - merely accepting the purchase by the AO - it was duty of the assessee to prove as to whether particular payees have incorporated in their books for computing their profits on the respective sales or not and we also noted from the submission of the assessee that there are contradictory submissions before the authorities below - Additions confirmed - AT
Addition u/s 40A - purchase by cash exceeding ₹ 20,000/- on various dates in one bill - merely accepting the purchase by the AO - it was duty of the assessee to prove as to whether particular payees have incorporated in their books for computing their profits on the respective sales or not and we also noted from the submission of the assessee that there are contradictory submissions before the authorities below - Additions confirmed - AT
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