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) - there is only a change of head of income and in the absence of any facts that the claim of the assessee was not bonafide - Tribunal was correct to delete penalty - HC
Penalty u/s 271(1)(c) - there is only a change of head of income and in the absence of any facts that the claim of the assessee was not bonafide - Tribunal was correct to delete penalty - HC
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