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...
Condonation of delay in claiming refund based on Tax Deducted at Source [TDS] - As the petitioner is being permitted to file revised returns on condonation of delay, if there is any occasion for the respondents to initiate proceedings u/s 143[2] for framing of assessment u/s 143[3] petitioner must be precluded from raising the defence of limitation. - HC
Condonation of delay in claiming refund based on Tax Deducted at Source [TDS] - As the petitioner is being permitted to file revised returns on condonation of delay, if there is any occasion for the respondents to initiate proceedings u/s 143[2] for framing of assessment u/s 143[3] petitioner must be precluded from raising the defence of limitation. - HC
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