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...
Disallowance u/s 14A - precondition of applicability of Sec 14A - interest paid on loan / borrowed funds - The tribunal held that the precondition of applicability of Section 14A had not been fulfilled in the present case and that there was no discussion as to how interest payment had been incurred in relation to some exempted income. Therefore, the disallowance made under Section 14A was directed to be deleted. - AT
Disallowance u/s 14A - precondition of applicability of Sec 14A - interest paid on loan / borrowed funds - The tribunal held that the precondition of applicability of Section 14A had not been fulfilled in the present case and that there was no discussion as to how interest payment had been incurred in relation to some exempted income. Therefore, the disallowance made under Section 14A was directed to be deleted. - AT
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