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 of interest expense paid u/s. 57 - nexus between the funds withdraw from the Partnership Firm and funds used for acquiring immovable property - if we apply the reasoning given in the immediate preceding paragraph that had the assessee not borrowed the money from the partnership firm on interest basis and would have taken the money out of the deposits made with the companies, there would not have been any question of the interest expenses whether capital or revenue in nature. - Claim allowed - AT
Disallowance of interest expense paid u/s. 57 - nexus between the funds withdraw from the Partnership Firm and funds used for acquiring immovable property - if we apply the reasoning given in the immediate preceding paragraph that had the assessee not borrowed the money from the partnership firm on interest basis and would have taken the money out of the deposits made with the companies, there would not have been any question of the interest expenses whether capital or revenue in nature. - Claim allowed - AT
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