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...
Special audit u/s. 142(2A) - Challenge on the ground that order is subjective satisfaction, is non-speaking and has been mechanically passed - The objection of petitioner that there is no material to show that interest of Revenue was adversely affected hence the special audit was not helpful, has no legs to stand in view of element of public interest being pre-dominant in the object behind special audit. - HC
Special audit u/s. 142(2A) - Challenge on the ground that order is subjective satisfaction, is non-speaking and has been mechanically passed - The objection of petitioner that there is no material to show that interest of Revenue was adversely affected hence the special audit was not helpful, has no legs to stand in view of element of public interest being pre-dominant in the object behind special audit. - HC
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