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...
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Levy of penalty u/s. 271(1)(c) - In the present case the assessee has demonstrated that the conditions specified in explanation 3 have not been fulfilled. He has pointed out that during the time period u/s 153 of the Act in the present case notice u/s 148 of the Act was issued to the assessee in response to which return was filed by him. - no penalty in the present case was leviable on the assessee for not having disclosed his income of capital gains earned on a property sold. - AT
Levy of penalty u/s. 271(1)(c) - In the present case the assessee has demonstrated that the conditions specified in explanation 3 have not been fulfilled. He has pointed out that during the time period u/s 153 of the Act in the present case notice u/s 148 of the Act was issued to the assessee in response to which return was filed by him. - no penalty in the present case was leviable on the assessee for not having disclosed his income of capital gains earned on a property sold. - AT
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