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...
Revision u/s 263 by CIT - Discrepancy in the claim of imported purchases as per the books and as per the CBEC data - assessee was only put to notice about the mismatch in import purchases. The issue of mismatch in export sales never being confronted to the assessee, the Ld.PCIT’s order holding the assessment order erroneous on this count is against all principles of natural justice and accordingly is set aside on this count. - AT
Revision u/s 263 by CIT - Discrepancy in the claim of imported purchases as per the books and as per the CBEC data - assessee was only put to notice about the mismatch in import purchases. The issue of mismatch in export sales never being confronted to the assessee, the Ld.PCIT’s order holding the assessment order erroneous on this count is against all principles of natural justice and accordingly is set aside on this count. - AT
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