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 - Jurisdiction to issue sanction - appropriate authority to grant approval for issuance of notice u/s. 148 - the approval for issuance of notice u/s. 148 ought not have been obtained from the Additional Commissioner of Income Tax but from the authority specifically mentioned u/s. 151(ii) of the Act - Notice quashed - HC
Reopening of assessment u/s 147 - Jurisdiction to issue sanction - appropriate authority to grant approval for issuance of notice u/s. 148 - the approval for issuance of notice u/s. 148 ought not have been obtained from the Additional Commissioner of Income Tax but from the authority specifically mentioned u/s. 151(ii) of the Act - Notice quashed - HC
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