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...
Revision u/s 263 by CIT - Applicability of Higher rate of tax u/s 115BBE on surrendered income - The applicability of the amended provision of section 115BBE of the Act, which prompted the PCIT to assume jurisdiction u/s 263 of the Act is highly debatable issue, and therefore wrongly assumed jurisdiction u/s 263. - AT
Revision u/s 263 by CIT - Applicability of Higher rate of tax u/s 115BBE on surrendered income - The applicability of the amended provision of section 115BBE of the Act, which prompted the PCIT to assume jurisdiction u/s 263 of the Act is highly debatable issue, and therefore wrongly assumed jurisdiction u/s 263. - AT
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