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 u/s 14A r.w rule 8D(2)(iii) - since there is no tax free income, there could not be any disallowance u/s 14A - AO directed to re-compute the income of the assessee after excluding the suo motto amount disallowed by the assessee. Apart from the above disallowance made by the AO on account of administrative expenses is concerned, this also stands deleted.
Disallowance u/s 14A r.w rule 8D(2)(iii) - since there is no tax free income, there could not be any disallowance u/s 14A - AO directed to re-compute the income of the assessee after excluding the suo motto amount disallowed by the assessee. Apart from the above disallowance made by the AO on account of administrative expenses is concerned, this also stands deleted.
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