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...
Jurisdiction of Commissioner (Appeals) - absense of protective show cause notice for recovery of interest - the non issuance of protective show cause notice does not create any estoppels to the Learned Commissioner (Appeals) for passing the Order in Appeal.- AT
Jurisdiction of Commissioner (Appeals) - absense of protective show cause notice for recovery of interest - the non issuance of protective show cause notice does not create any estoppels to the Learned Commissioner (Appeals) for passing the Order in Appeal.- AT
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