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...
Penalty u/s. 271F - The filing of return beyond the due date is admittedly invalid return as there is no provision for filing the return belatedly once notice u/s.153A has been issued. This being so, we are of the view that the assessee had a valid ground for non-filing of return. - No penalty - AT
Penalty u/s. 271F - The filing of return beyond the due date is admittedly invalid return as there is no provision for filing the return belatedly once notice u/s.153A has been issued. This being so, we are of the view that the assessee had a valid ground for non-filing of return. - No penalty - AT
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