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...
Claim of exemption u/s. 10(22) and section 10(23C)(vi) - The respondents have not substantiated their bald statement that ASB/the petitioners have not invested the surplus money in accordance with law which in any event would not be a criteria at the initial stage of approval as held by the Apex Court in New Noble Society (supra). - Benefit of exemption allowed - HC
Claim of exemption u/s. 10(22) and section 10(23C)(vi) - The respondents have not substantiated their bald statement that ASB/the petitioners have not invested the surplus money in accordance with law which in any event would not be a criteria at the initial stage of approval as held by the Apex Court in New Noble Society (supra). - Benefit of exemption allowed - HC
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