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...
Offence u/s 276C(1) - CIT(A) while deleting the penalty held that, The Commissioner of Income Tax, Appeal held in the appeal No.16/10060/2019-20, the petitioner was under bonafide belief that there was no tax liability to be discharged by him on account of his residential status as NRE accounts and the TDS made by the bank. - once the penalty on the petitioner was deleted, the prosecution initiated by the respondent cannot be sustained. - HC
Offence u/s 276C(1) - CIT(A) while deleting the penalty held that, The Commissioner of Income Tax, Appeal held in the appeal No.16/10060/2019-20, the petitioner was under bonafide belief that there was no tax liability to be discharged by him on account of his residential status as NRE accounts and the TDS made by the bank. - once the penalty on the petitioner was deleted, the prosecution initiated by the respondent cannot be sustained. - HC
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