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...
Revision u/s 263 by CIT - write off of the investment in subsidiary under the Normal provisions and under the computation of Book Profits u/s 115JB - . Merely because the AO, after calling for explanation and satisfying himself, has not mentioned the same in his Assessment order would not mean that he has not applied his mind on the specific submissions of the Appellant - on merits also, the claim of investment written off is an allowable deduction - AT
Revision u/s 263 by CIT - write off of the investment in subsidiary under the Normal provisions and under the computation of Book Profits u/s 115JB - . Merely because the AO, after calling for explanation and satisfying himself, has not mentioned the same in his Assessment order would not mean that he has not applied his mind on the specific submissions of the Appellant - on merits also, the claim of investment written off is an allowable deduction - AT
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