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...
Rectification u/s 154 - Capital gain computation - Having admitted to this mistake in his order, there was no other recourse available in law to the Ld.CIT(A) other than allowing assessee’s rectification application. His dismissal of the rectification application on the ground that it would change the CIT(A)’s order is in blatant disregard and against all settled principles of law. If a mistake is admitted to have occurred in an order, the same needs to be rectified. There are no two ways about it. - AT
Rectification u/s 154 - Capital gain computation - Having admitted to this mistake in his order, there was no other recourse available in law to the Ld.CIT(A) other than allowing assessee’s rectification application. His dismissal of the rectification application on the ground that it would change the CIT(A)’s order is in blatant disregard and against all settled principles of law. If a mistake is admitted to have occurred in an order, the same needs to be rectified. There are no two ways about it. - AT
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