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 the re-opening of the assessment - non-issuance of notice u/s. 143(2) - In the absence of such notice, it is presumed that AO did not issue any notice u/s. 143(2) of the Act, hence the assessment was framed without meeting the requirement of law. - assessment order quashed being bad in law - AT
Validity of the re-opening of the assessment - non-issuance of notice u/s. 143(2) - In the absence of such notice, it is presumed that AO did not issue any notice u/s. 143(2) of the Act, hence the assessment was framed without meeting the requirement of law. - assessment order quashed being bad in law - AT
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