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...
Deduction u/s 54 - LTCG invested in buying two residential units - the assessee would only entitle to the benefit of section 54, 1) if the assessee invested the LTCG amount for buying one residential house or 2) if the assessee purchased one residential house which was made after merger of two residential units already amalgamated and were in existence as one residential unit - However the assessee is not entitled to benefit of LTCG invested in buying two residential units and thereafter converting the said two residential units as one. - AT
Deduction u/s 54 - LTCG invested in buying two residential units - the assessee would only entitle to the benefit of section 54, 1) if the assessee invested the LTCG amount for buying one residential house or 2) if the assessee purchased one residential house which was made after merger of two residential units already amalgamated and were in existence as one residential unit - However the assessee is not entitled to benefit of LTCG invested in buying two residential units and thereafter converting the said two residential units as one. - AT
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