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...
Disallowance of expenditure owing to suspension of business operations - To our mind, not carrying on any business activities during a particular period cannot be equated with closure of business since it will lead to a narrow view of the scope of cessation of business. There is nothing on record to show that assessee has completely abandoned or closed the business forever by disposing of its assets and going into liquidation. - Appeal of the revenue dismissed - AT
Disallowance of expenditure owing to suspension of business operations - To our mind, not carrying on any business activities during a particular period cannot be equated with closure of business since it will lead to a narrow view of the scope of cessation of business. There is nothing on record to show that assessee has completely abandoned or closed the business forever by disposing of its assets and going into liquidation. - Appeal of the revenue dismissed - AT
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