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...
Penalty u/s 271(1)(c) - Defective notice u/s 274 - in the assessment order, AO has made it clear that penalty proceedings are initiated separately for furnishing inaccurate particulars of income, therefore the AO has already indicated that why the penalty proceedings are initiated. - Though the notice u/s 274 has been found as valid, the penalty levied on the estimation of income deleted - AT
Penalty u/s 271(1)(c) - Defective notice u/s 274 - in the assessment order, AO has made it clear that penalty proceedings are initiated separately for furnishing inaccurate particulars of income, therefore the AO has already indicated that why the penalty proceedings are initiated. - Though the notice u/s 274 has been found as valid, the penalty levied on the estimation of income deleted - AT
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