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...
Reopening of assessment u/s 147 - reasons to believe that income had escaped tax - According to the AO he was satisfied that there was insider trading amongst two family members by which the income which had become chargeable to tax was not shown and had escaped the assessment requiring to exercise powers for reopening of the assessment. There was a strong foundation for invoking reassessment. - Reopening sustained - HC
Reopening of assessment u/s 147 - reasons to believe that income had escaped tax - According to the AO he was satisfied that there was insider trading amongst two family members by which the income which had become chargeable to tax was not shown and had escaped the assessment requiring to exercise powers for reopening of the assessment. There was a strong foundation for invoking reassessment. - Reopening sustained - HC
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