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...
Adjustment made u/s.143(1) - incorrect computation of allowable MAT credit u/s 115JAA - there cannot be any debate as to the exclusion of surcharge and cess - this issue is not amenable to any prima-facie adjustment as provided in section 143(1). Though, assessee has not raised this aspect, before Ld.CIT(A), there is no estoppel as to law. Hence, we hold that this adjustment was not liable to be made u/s. 143(1). - AT
Adjustment made u/s.143(1) - incorrect computation of allowable MAT credit u/s 115JAA - there cannot be any debate as to the exclusion of surcharge and cess - this issue is not amenable to any prima-facie adjustment as provided in section 143(1). Though, assessee has not raised this aspect, before Ld.CIT(A), there is no estoppel as to law. Hence, we hold that this adjustment was not liable to be made u/s. 143(1). - AT
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