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...
Addition u/s 69C - value of asset bought from the vendor who is alleged to be a suspicious dealer - disallowance of depreciation on the asset above - the AO cannot disallow the total value of the asset and also simultaneously disallow the depreciation claimed by the assessee. The disallowance can only be made to the extent of the benefit claimed by the assessee under the Act. - AT
Addition u/s 69C - value of asset bought from the vendor who is alleged to be a suspicious dealer - disallowance of depreciation on the asset above - the AO cannot disallow the total value of the asset and also simultaneously disallow the depreciation claimed by the assessee. The disallowance can only be made to the extent of the benefit claimed by the assessee under the Act. - AT
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