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...
Penalty u/s.271(1)(b) - no compliance to notice u/s 142(1) - The AO levied the penalty for non-compliance of notice dated 13.06.2016, however, there is no reference of such notice for the assessment order, therefore, the order in levying penalty under section 271(1)(b) is invalid. - Furthermore, hen assessee itself offered additional income, which was debited on account of interest on TDS and the same was accepted by AO. And no other issue was identified nor was any other addition made in the assessment order, no penalty should be levied - AT
Penalty u/s.271(1)(b) - no compliance to notice u/s 142(1) - The AO levied the penalty for non-compliance of notice dated 13.06.2016, however, there is no reference of such notice for the assessment order, therefore, the order in levying penalty under section 271(1)(b) is invalid. - Furthermore, hen assessee itself offered additional income, which was debited on account of interest on TDS and the same was accepted by AO. And no other issue was identified nor was any other addition made in the assessment order, no penalty should be levied - AT
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