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...
Validity of penalty levied u/s 271(1)(b) - non-compliance - The assessee has shown sufficient cause for non-compliance, moreover, such non-compliance was done by granting adjournment by the AO himself. - the assessment was framed u/s 143(3) - the penalty u/s 271(1)(b) of the Act cannot be imposed on the assessee for such bonafide default due to reasons beyond his control - AT
Validity of penalty levied u/s 271(1)(b) - non-compliance - The assessee has shown sufficient cause for non-compliance, moreover, such non-compliance was done by granting adjournment by the AO himself. - the assessment was framed u/s 143(3) - the penalty u/s 271(1)(b) of the Act cannot be imposed on the assessee for such bonafide default due to reasons beyond his control - AT
Note: It is a system-generated summary and is for quick reference only.