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...
Levying penalty u/s 272A(1)(d) - non-compliance of correspondences for special audit u/s 142(2A) - AO has written a letter to the Auditor for special audit of four case including the appellants but, the AO had never issue a specific notice with point of special audit to the appellant assessee u/s 142(2A) of the Act with the Approval of the PCIT. - No penalty - AT
Levying penalty u/s 272A(1)(d) - non-compliance of correspondences for special audit u/s 142(2A) - AO has written a letter to the Auditor for special audit of four case including the appellants but, the AO had never issue a specific notice with point of special audit to the appellant assessee u/s 142(2A) of the Act with the Approval of the PCIT. - No penalty - AT
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