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...
Adjustment of refunds granted for computing of interest u/s 244A - the manner in which the assessing officer has adjusted the refund is not correct and that the assessee would be entitled for interest on the unpaid refunds in accordance with the principle laid out in the aforesaid decision of Tribunal. AO is directed to compute interest under section 244A as per the claim of the assessee after giving a proper opportunity of being heard. - AT
Adjustment of refunds granted for computing of interest u/s 244A - the manner in which the assessing officer has adjusted the refund is not correct and that the assessee would be entitled for interest on the unpaid refunds in accordance with the principle laid out in the aforesaid decision of Tribunal. AO is directed to compute interest under section 244A as per the claim of the assessee after giving a proper opportunity of being heard. - AT
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