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...
Deduction of expenditure from income taxable under the head "From Other Sources" - Car Lease rental income - A plain reading of section 57 (iii) of the Act would lead one to the conclusion that it does not say that the expenditure shall be deductible only if any net positive income is made or earned. Therefore, there can even be a negative income/loss u/s. 57(iii) of the Act. Therefore, by this reasoning also, CIT(A) was incorrect in directing that the amount of deduction should be restricted to the income earned. - AT
Deduction of expenditure from income taxable under the head "From Other Sources" - Car Lease rental income - A plain reading of section 57 (iii) of the Act would lead one to the conclusion that it does not say that the expenditure shall be deductible only if any net positive income is made or earned. Therefore, there can even be a negative income/loss u/s. 57(iii) of the Act. Therefore, by this reasoning also, CIT(A) was incorrect in directing that the amount of deduction should be restricted to the income earned. - AT
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