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) - Penalty order did not specify the particular limb under which penalty u/s 271(1)(c) is levied. AO has not specified that penalty is either levied for furnishing inaccurate particulars of income or for concealing the income. The AO himself is not clear that penalty is either levied for concealment of income or for furnishing inaccurate particulars - No penalty - AT
Penalty u/s 271(1)(c) - Penalty order did not specify the particular limb under which penalty u/s 271(1)(c) is levied. AO has not specified that penalty is either levied for furnishing inaccurate particulars of income or for concealing the income. The AO himself is not clear that penalty is either levied for concealment of income or for furnishing inaccurate particulars - No penalty - AT
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