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 - Exemption claimed u/s 80 IB(11- C) - If certain assessment order was made by the Income Tax Officer the same could not be branded as erroneous by the Principal Commissioner of Income Tax merely because another view was possible - the Tribunal did not commit any error in holding that such enquiry was made by the Assessing Officer and hence there was no reason for the Pr. CIT to invoke jurisdiction u/s 263. - HC
Revision u/s 263 - Exemption claimed u/s 80 IB(11- C) - If certain assessment order was made by the Income Tax Officer the same could not be branded as erroneous by the Principal Commissioner of Income Tax merely because another view was possible - the Tribunal did not commit any error in holding that such enquiry was made by the Assessing Officer and hence there was no reason for the Pr. CIT to invoke jurisdiction u/s 263. - HC
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