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 by CIT - entitlement u/s 10(23C)(iiiab) - the appellant neither during the assessment proceeding nor during revisionary proceeding submitted any details in relation to the donations showcasing its genuineness and further no evidential material found placed in substantiating the genuineness of cash expenditure incurred - Revision order and additions confirmed - AT
Revision u/s 263 by CIT - entitlement u/s 10(23C)(iiiab) - the appellant neither during the assessment proceeding nor during revisionary proceeding submitted any details in relation to the donations showcasing its genuineness and further no evidential material found placed in substantiating the genuineness of cash expenditure incurred - Revision order and additions confirmed - AT
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