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...
Revision u/s 263 - the head of assessee’s income derived from its holiday homes i.e. whether it is income from house property as per the PCIT, business income going by the AO in assessment and the CIT(A) and the residuary had of “other” sources in its computation; respectively, is purely a debatable issue. - Assumption of jurisdiction u/s 263 is not proper.
Revision u/s 263 - the head of assessee’s income derived from its holiday homes i.e. whether it is income from house property as per the PCIT, business income going by the AO in assessment and the CIT(A) and the residuary had of “other” sources in its computation; respectively, is purely a debatable issue. - Assumption of jurisdiction u/s 263 is not proper.
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