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...
Settlement of a Case - receipt of the application u/s 245C(1) - Procedure u/s 245D - Whether full and true disclosure of income while making application under Section 245(C)? - the application before the Commission deserved to be rejected as the respondents had not made true and full disclosure of their undisclosed income. This issue is decided in favour of the revenue. - HC
Settlement of a Case - receipt of the application u/s 245C(1) - Procedure u/s 245D - Whether full and true disclosure of income while making application under Section 245(C)? - the application before the Commission deserved to be rejected as the respondents had not made true and full disclosure of their undisclosed income. This issue is decided in favour of the revenue. - HC
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