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...
Reopening of assessment u/s 147 - Income deemed to accrue or arise in India - writ against the show cause notice - Looking into the spirit of Section 9(1)(i) of the Act, in the context of the contents made in the show cause notice, it is sufficient to form an opinion that the matter requires effective and elaborate adjudication in order to cull out the truth with reference to the pleadings and grounds raised by the petitioner. - HC
Reopening of assessment u/s 147 - Income deemed to accrue or arise in India - writ against the show cause notice - Looking into the spirit of Section 9(1)(i) of the Act, in the context of the contents made in the show cause notice, it is sufficient to form an opinion that the matter requires effective and elaborate adjudication in order to cull out the truth with reference to the pleadings and grounds raised by the petitioner. - HC
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