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 - Period of limitation - the limitation prescribed under section 263(2) would run from original assessment in respect of issue alien to reasons recorded. Thus, when seen qua the original assessment, the revisional order on the second issue is clearly barred by limitation. The action of the PCIT on the second issue thus cannot be countenanced. - AT
Revision u/s 263 - Period of limitation - the limitation prescribed under section 263(2) would run from original assessment in respect of issue alien to reasons recorded. Thus, when seen qua the original assessment, the revisional order on the second issue is clearly barred by limitation. The action of the PCIT on the second issue thus cannot be countenanced. - AT
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