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)(c) - when the assessee has explained the entries with necessary evidences and said explanation is not found to be false, then merely for the reason that assessee had accepted addition made towards particular income is not a ground to hold that the assessee has furnished inaccurate particulars of income, which warrants levy of penalty u/s.271(1)(c) - AT
Penalty u/s 271(1)(c) - when the assessee has explained the entries with necessary evidences and said explanation is not found to be false, then merely for the reason that assessee had accepted addition made towards particular income is not a ground to hold that the assessee has furnished inaccurate particulars of income, which warrants levy of penalty u/s.271(1)(c) - AT
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