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...
Assessment to be framed u/s 153C OR u/s 147/148 - Validity of the reassessment proceedings - Initiation of action u/s 153C would arise only if the seized material are handed over to the AO of such other person having jurisdiction of such other person - It is no so in the present case - no fault in the initiation of proceedings u/s 147/148 - AT
Assessment to be framed u/s 153C OR u/s 147/148 - Validity of the reassessment proceedings - Initiation of action u/s 153C would arise only if the seized material are handed over to the AO of such other person having jurisdiction of such other person - It is no so in the present case - no fault in the initiation of proceedings u/s 147/148 - AT
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