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 271(1)(c) - Error in computing LTCG - Based on the facts, AI ought to have accepted the claim of the assessee that the claim of loss was not intentional. - Moreover, as observed by the CIT(A) reduction in capital loss cannot be considered for imposition of penalty. - Revenue appeal dismissed - HC
Penalty u/s 271(1)(c) - Error in computing LTCG - Based on the facts, AI ought to have accepted the claim of the assessee that the claim of loss was not intentional. - Moreover, as observed by the CIT(A) reduction in capital loss cannot be considered for imposition of penalty. - Revenue appeal dismissed - HC
Note: It is a system-generated summary and is for quick reference only.