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 - Capital gain computation - the out of 100 % sales consideration 95.36 % is offered as capital gain and the claim of the assessee is less than 5 % of the total consideration in this case, thus, what more AO can find fault when he has already disallowed the cost which in his opinion is not supported and thus AO has already verified the issues which the PCIT is pointing out - Order of AO restored - AT
Revision u/s 263 by CIT - Capital gain computation - the out of 100 % sales consideration 95.36 % is offered as capital gain and the claim of the assessee is less than 5 % of the total consideration in this case, thus, what more AO can find fault when he has already disallowed the cost which in his opinion is not supported and thus AO has already verified the issues which the PCIT is pointing out - Order of AO restored - AT
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