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...
Admissibility of additional evidences under Rule 46A - Power of CIT(A) - Penalty u/s 271D - taking cash loan - Default under provisions of section 269SS - proof of bona fides and genuiness of the transaction - “reasonable cause” - the ld. CIT(A) has to pass a speaking order in writing as to his decision as to admission or refusal to admit additional evidences. - ld. CIT(A) did not comply with Rule 46A of the 1962 Rules. - Matter restored back - AT
Admissibility of additional evidences under Rule 46A - Power of CIT(A) - Penalty u/s 271D - taking cash loan - Default under provisions of section 269SS - proof of bona fides and genuiness of the transaction - “reasonable cause” - the ld. CIT(A) has to pass a speaking order in writing as to his decision as to admission or refusal to admit additional evidences. - ld. CIT(A) did not comply with Rule 46A of the 1962 Rules. - Matter restored back - AT
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