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...
Penalty u/s. 271B - assessee had not filed audit report - Only a qualified CA is permitted to Audit books of account. In the affidavit it is claimed by the Accountant of the firm, that he had not given data to CA. Thus, in the affidavit he is not referring to books. However, for Audit, books of account are required. Therefore, the claims made in the affidavit are contradictory and hence not reliable. - Levy of penalty confirmed - AT
Penalty u/s. 271B - assessee had not filed audit report - Only a qualified CA is permitted to Audit books of account. In the affidavit it is claimed by the Accountant of the firm, that he had not given data to CA. Thus, in the affidavit he is not referring to books. However, for Audit, books of account are required. Therefore, the claims made in the affidavit are contradictory and hence not reliable. - Levy of penalty confirmed - AT
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