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 Assessment u/s 153C - Notice issued by any officer other than jurisdictional AO - the entire conspectus of the case, it appears that the AO had recorded the satisfaction note prior to assuming jurisdiction over the case of the assessee as the AO got charge over the case of the assessee on 02-09-2019 - CIT(A) is not justified in sustaining the action of the AO in holding that the AO has assumed proper jurisdiction to assess the case u/s. 153C - AT
Validity of Assessment u/s 153C - Notice issued by any officer other than jurisdictional AO - the entire conspectus of the case, it appears that the AO had recorded the satisfaction note prior to assuming jurisdiction over the case of the assessee as the AO got charge over the case of the assessee on 02-09-2019 - CIT(A) is not justified in sustaining the action of the AO in holding that the AO has assumed proper jurisdiction to assess the case u/s. 153C - AT
Note: It is a system-generated summary and is for quick reference only.