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 271D & 271E - Contravention of provisions of Section 269SS & 269TT - Accepting and repayment of loans / deposits in Cash from the Managing Director of the Assessee Company - The justification given by the assessee for receiving loans in cash is unsubstantiated, as they received and repaid huge amounts without reasonable cause. Therefore, the penalty is justified. - AT
Penalty u/s 271D & 271E - Contravention of provisions of Section 269SS & 269TT - Accepting and repayment of loans / deposits in Cash from the Managing Director of the Assessee Company - The justification given by the assessee for receiving loans in cash is unsubstantiated, as they received and repaid huge amounts without reasonable cause. Therefore, the penalty is justified. - AT
Note: It is a system-generated summary and is for quick reference only.