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...
Assets leased out to various companies - Whether assets were in existence at the relevant time and whether the transactions in question were genuine or not - finding of fact - The aforesaid finding of fact has been affirmed by the Income Tax Appellate Tribunal. Thus, the matter stands concluded by concurrent findings of fact, which by no stretch of imagination can be said to be either based on no evidence or perverse. - Depreciation allowed - HC
Assets leased out to various companies - Whether assets were in existence at the relevant time and whether the transactions in question were genuine or not - finding of fact - The aforesaid finding of fact has been affirmed by the Income Tax Appellate Tribunal. Thus, the matter stands concluded by concurrent findings of fact, which by no stretch of imagination can be said to be either based on no evidence or perverse. - Depreciation allowed - HC
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