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 levied u/s. 271G - nternational transactions - assessee ignoring the provisions of Section 92D of the Act as well as Rule 10D of the Income Tax Rules - Section 273B of the Act provides for reasonable cause and if that is justified, penalty/s. 271G of the Act may not be imposed and when this opportunity is given to the assessee by the statutes itself and the assessee has explained the reasonable causes which was accepted by the Ld. CIT(Appeal) and after perusing such reasons, we are in conformity with the findings of the Ld. CIT(Appeals). - AT
Penalty levied u/s. 271G - nternational transactions - assessee ignoring the provisions of Section 92D of the Act as well as Rule 10D of the Income Tax Rules - Section 273B of the Act provides for reasonable cause and if that is justified, penalty/s. 271G of the Act may not be imposed and when this opportunity is given to the assessee by the statutes itself and the assessee has explained the reasonable causes which was accepted by the Ld. CIT(Appeal) and after perusing such reasons, we are in conformity with the findings of the Ld. CIT(Appeals). - AT
Note: It is a system-generated summary and is for quick reference only.