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...
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
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