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 - Addition u/s 54 - sale of property - Merely there is an observation of the revenue audit party it is not a mistake apparent on record. - There exist no mistake which is apparent on record. The law duly empowers the revenue to invoke other provision to consider the audit objection but the same is not permitted under the provision of section 154 of the Act as it done by the AO. - AT
Rectification u/s 154 - Addition u/s 54 - sale of property - Merely there is an observation of the revenue audit party it is not a mistake apparent on record. - There exist no mistake which is apparent on record. The law duly empowers the revenue to invoke other provision to consider the audit objection but the same is not permitted under the provision of section 154 of the Act as it done by the AO. - AT
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