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...
Condonation of delay - sufficient cause - Request for Reopening of assessment order for accepting declarations in Form ‘C’ - power of authorities to reopen the proceedings after lapse of four years - no material particulars are placed on record with regard to the date of such closure - as no ‘sufficient cause’ has been made out by the petitioner to explain the delay in filing declarations in Form ‘C’, we are of the opinion no case for directing to reopen the assessment is made out. - HC
Condonation of delay - sufficient cause - Request for Reopening of assessment order for accepting declarations in Form ‘C’ - power of authorities to reopen the proceedings after lapse of four years - no material particulars are placed on record with regard to the date of such closure - as no ‘sufficient cause’ has been made out by the petitioner to explain the delay in filing declarations in Form ‘C’, we are of the opinion no case for directing to reopen the assessment is made out. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
