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 - estimation of income on bogus purchases - Keeping in view the applicable VAT rate, Ld. AO estimated a further addition of 1.6% against these purchases. - Merely because Ld. Pr. CIT held a view that the estimation should have been at higher rates or entire purchase should have been disallowed, the same would not make the order erroneous - AT
Revision u/s 263 - estimation of income on bogus purchases - Keeping in view the applicable VAT rate, Ld. AO estimated a further addition of 1.6% against these purchases. - Merely because Ld. Pr. CIT held a view that the estimation should have been at higher rates or entire purchase should have been disallowed, the same would not make the order erroneous - AT
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