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 68 - unexplained cash credit - Assessee has discharged the primary onus to demonstrate fulfilment of primary ingredients of Sec.68 and it was incumbent upon revenue to dislodge the assessee’s claim by bringing on record, cogent material to establish that the assessee’s unaccounted money was routed in its books of account in the garb of unsecured loans
Addition u/s 68 - unexplained cash credit - Assessee has discharged the primary onus to demonstrate fulfilment of primary ingredients of Sec.68 and it was incumbent upon revenue to dislodge the assessee’s claim by bringing on record, cogent material to establish that the assessee’s unaccounted money was routed in its books of account in the garb of unsecured loans
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