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...
Addition u/s 68 - capital introduced by the partners - disallowed the interest paid to the partners - if at all, if the respondent-Department was not satisfied with the explanation, it was for them to have got it verified from the partners. Rather than still pursuing the matter before the appellant’s partnership firm, which is otherwise impermissible. - Order of ITAT against the assessee quashed - HC
Addition u/s 68 - capital introduced by the partners - disallowed the interest paid to the partners - if at all, if the respondent-Department was not satisfied with the explanation, it was for them to have got it verified from the partners. Rather than still pursuing the matter before the appellant’s partnership firm, which is otherwise impermissible. - Order of ITAT against the assessee quashed - HC
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