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...
Revision u/s 263 - disallowance u/s 14A r.w.r. 8D - the assessee has not incurred any indirect expenses to earn the exempt income and ld. PCIT has not brought any material to show that the assessee has incurred indirect expenses to earn the exempt income. - PCIT has erred in invoking the provisions of Section 263 - AT
Revision u/s 263 - disallowance u/s 14A r.w.r. 8D - the assessee has not incurred any indirect expenses to earn the exempt income and ld. PCIT has not brought any material to show that the assessee has incurred indirect expenses to earn the exempt income. - PCIT has erred in invoking the provisions of Section 263 - AT
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