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. 270A - GP estimation - underreporting of income - The AO failed to prove underreporting, and the penalty for underreporting of income u/s 270A cannot be imposed based on an estimate. As the addition was made on GP estimation, the penalty is not maintainable, and the AO directed to delete it. - AT
Penalty u/s. 270A - GP estimation - underreporting of income - The AO failed to prove underreporting, and the penalty for underreporting of income u/s 270A cannot be imposed based on an estimate. As the addition was made on GP estimation, the penalty is not maintainable, and the AO directed to delete it. - AT
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