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. 272A(1)(d) - non compliance to notice u/s. 142(1) due to covid pandemic - addition u/s. 68 - As it is observed that when there is a reasonable cause for the said failure, the penalty imposed u/s. 272A sub section (1) of the Act is protected as per the provision of section 272B where the penalty shall not be imposed when the assessee has substantiated reasonable cause for such failure. - AT
Penalty u/s. 272A(1)(d) - non compliance to notice u/s. 142(1) due to covid pandemic - addition u/s. 68 - As it is observed that when there is a reasonable cause for the said failure, the penalty imposed u/s. 272A sub section (1) of the Act is protected as per the provision of section 272B where the penalty shall not be imposed when the assessee has substantiated reasonable cause for such failure. - AT
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