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...
Disallowance u/s 40(a)(ia) - Non deduction of TDS u/s 194A - Interest - the provisions of section 194A have no application in case where no interest is credited to the account of the parties nor was paid during the previous year relevant to the assessment year under consideration. - Additions deleted - AT
Disallowance u/s 40(a)(ia) - Non deduction of TDS u/s 194A - Interest - the provisions of section 194A have no application in case where no interest is credited to the account of the parties nor was paid during the previous year relevant to the assessment year under consideration. - Additions deleted - AT
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