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...
Reopening of assessment u/s 147 - notice passed u/s.148 was not signed by the AO digitally or manually - not a curable defect u/s 292B - - The notice u/s.148 having no signature affixed on it, digitally or manually, the same is invalid and would not vest the Assessing Officer with any further jurisdiction to proceed to reassess the income of the petitioner. - HC
Reopening of assessment u/s 147 - notice passed u/s.148 was not signed by the AO digitally or manually - not a curable defect u/s 292B - - The notice u/s.148 having no signature affixed on it, digitally or manually, the same is invalid and would not vest the Assessing Officer with any further jurisdiction to proceed to reassess the income of the petitioner. - HC
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