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...
Revision u/s 263 by CIT - As per PCIT AO fails to examine the issue on increase in share premium in light of provisions of section 56(2)(vii), although, the assessee has made huge cash deposits during demonetization period, the AO has not verified the issue in light of SOP issued by CBDT for verification - Revision proceedings sustained - AT
Revision u/s 263 by CIT - As per PCIT AO fails to examine the issue on increase in share premium in light of provisions of section 56(2)(vii), although, the assessee has made huge cash deposits during demonetization period, the AO has not verified the issue in light of SOP issued by CBDT for verification - Revision proceedings sustained - AT
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