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...
Addition u/s 69A - unexplained investment in the bank account - Though there is no specific evidence but the circumstances of the assessee and his lifestyle do suggest that the expression “may” used in Section 69A of the Act, has to be used here. This expression “may” infused discretion in the Assessing Officer to treat such an investment as explained or unexplained investment - Additions deleted - AT
Addition u/s 69A - unexplained investment in the bank account - Though there is no specific evidence but the circumstances of the assessee and his lifestyle do suggest that the expression “may” used in Section 69A of the Act, has to be used here. This expression “may” infused discretion in the Assessing Officer to treat such an investment as explained or unexplained investment - Additions deleted - AT
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