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...
Rectification of mistake - typographical order - The mistake as alleged is not at all self evident, hence cannot be called as error apparent on record. As for as the plea of cum-tax-benefit is concerned, the plea has not been raised in grounds of appeal. The allegation that the same was not considered by this Tribunal despite been submitted is, therefore, not sustainable.
Rectification of mistake - typographical order - The mistake as alleged is not at all self evident, hence cannot be called as error apparent on record. As for as the plea of cum-tax-benefit is concerned, the plea has not been raised in grounds of appeal. The allegation that the same was not considered by this Tribunal despite been submitted is, therefore, not sustainable.
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