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 - Order of the AO in respect of unsecured loans, sundry creditors/liabilities and sundry debtors accepted by the AO is erroneous and prejudicial to the interest of revenue. We hereby make it clear that the direction of the ld. Pr.CIT in respect of stock differences found from the record is not required to further verification and in respect of unsecured loans, sundry creditors/liabilities and sundry debtors the AO has to follow the direction of the ld. Pr.CIT. - AT
Revision u/s 263 - Order of the AO in respect of unsecured loans, sundry creditors/liabilities and sundry debtors accepted by the AO is erroneous and prejudicial to the interest of revenue. We hereby make it clear that the direction of the ld. Pr.CIT in respect of stock differences found from the record is not required to further verification and in respect of unsecured loans, sundry creditors/liabilities and sundry debtors the AO has to follow the direction of the ld. Pr.CIT. - AT
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