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...
Non-deduction of TDS - It is a fact on record that the amounts of provisions created by the appellant on which TDS was not deducted had been duly included by the deductee in the return of income filed for the year in which the amounts were actually received by the deductee and in which the invoices were raised. As such no demand u/s 201(1) is justified - AT
Non-deduction of TDS - It is a fact on record that the amounts of provisions created by the appellant on which TDS was not deducted had been duly included by the deductee in the return of income filed for the year in which the amounts were actually received by the deductee and in which the invoices were raised. As such no demand u/s 201(1) is justified - AT
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