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 - The assessee in its support had complied the requirements as raised by both the revenue authorities. Though the assessment order does not patently indicate that the issue in question had been considered by the AO, the record showed that the AO had applied his mind - Thus investigation by the ld. AO cannot be called ‘lack of investigation’. - AT
Revision u/s 263 by CIT - The assessee in its support had complied the requirements as raised by both the revenue authorities. Though the assessment order does not patently indicate that the issue in question had been considered by the AO, the record showed that the AO had applied his mind - Thus investigation by the ld. AO cannot be called ‘lack of investigation’. - AT
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