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 271D and penalty u/s. 271E - Default u/s 269SS and u/s 269T - Loan/deposits taken/paid by the assessee in cash is more than Rs.20,000/- - after evaluating the provisions of law, aggregate of loan is to be seen personwise and not aggregate loan taken from all the persons in the whole year. Therefore, under these present facts and circumstances of the case, the penalty is not attracted in the present case- AT
Penalty u/s 271D and penalty u/s. 271E - Default u/s 269SS and u/s 269T - Loan/deposits taken/paid by the assessee in cash is more than Rs.20,000/- - after evaluating the provisions of law, aggregate of loan is to be seen personwise and not aggregate loan taken from all the persons in the whole year. Therefore, under these present facts and circumstances of the case, the penalty is not attracted in the present case- AT
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