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...
Addition u/s 56(2) - Allotment of shares - price less than the FMV - Merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. - AT
Addition u/s 56(2) - Allotment of shares - price less than the FMV - Merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. - AT
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