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...
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Revision u/s 263 by CIT - Unexplained Cash deposited in the bank account - taxability of profit @ 8% u/s. 44AD - This action of the assessee was accepted by the AO without realising that provisions of section 44AD of the Act do not apply to a commission agent thereby making the assessment order erroneous in law and because of this error the AO did not examine the cash deposit making the assessment order pre judicial to the interest of the revenue. - AT
Revision u/s 263 by CIT - Unexplained Cash deposited in the bank account - taxability of profit @ 8% u/s. 44AD - This action of the assessee was accepted by the AO without realising that provisions of section 44AD of the Act do not apply to a commission agent thereby making the assessment order erroneous in law and because of this error the AO did not examine the cash deposit making the assessment order pre judicial to the interest of the revenue. - AT
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