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...
Levy of penalties - Extended period of limitation - the department has not brought in any evidence on record to substantiate the allegation of fraud, collusion, suppression or misrepresentation of fact. Thus, extended period cannot be invoked in respect of these demands and hence no penalty imposable on this demand. - AT
Levy of penalties - Extended period of limitation - the department has not brought in any evidence on record to substantiate the allegation of fraud, collusion, suppression or misrepresentation of fact. Thus, extended period cannot be invoked in respect of these demands and hence no penalty imposable on this demand. - AT
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