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...
Deemed dividend under Section 2(22)(e) - addition only qua the peak amount - Whether addition should be restricted to the peak amount of the loans given during the year? - Deeming fiction of dividend under Section 2(22)(e) comes to play regarding each and every sum received by the concerned assessee - AT
Deemed dividend under Section 2(22)(e) - addition only qua the peak amount - Whether addition should be restricted to the peak amount of the loans given during the year? - Deeming fiction of dividend under Section 2(22)(e) comes to play regarding each and every sum received by the concerned assessee - AT
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