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...
Validity of Appeal filed by AOP having PAN issued as Individual - CIT(A) did not adjudicate the issue on merits in accordance with the provisions of section 250(6) of the Act, rather dismissed the appeal of the assessee, stating that AOP has used Individual PAN Number. We note that defect in form no. 35 is a curable defect. The ld. CIT(A) should have asked the assessee to correct form no.35, and remove the defect. With these facts, we are of the view that appeal of the AOP is maintainable in law. - AT
Validity of Appeal filed by AOP having PAN issued as Individual - CIT(A) did not adjudicate the issue on merits in accordance with the provisions of section 250(6) of the Act, rather dismissed the appeal of the assessee, stating that AOP has used Individual PAN Number. We note that defect in form no. 35 is a curable defect. The ld. CIT(A) should have asked the assessee to correct form no.35, and remove the defect. With these facts, we are of the view that appeal of the AOP is maintainable in law. - AT
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