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...
Reopening of assessment u/s 147 - reasons to believe - notice u/s 148A(b) - the case of the petitioner is covered by information specified in Explanation 1(i) of Section 148 of the IT Act. It is not the case of the petitioner that information disclosed vide notice under Section 148A(b) of the IT Act is not covered by the information specified in Explanation 1(i) of Section 148 of the IT Act. - We respectfully disagree with the judgment of Charu Chains and Jewels Pvt. Ltd. [2023 (1) TMI 486 - DELHI HIGH COURT] - HC
Reopening of assessment u/s 147 - reasons to believe - notice u/s 148A(b) - the case of the petitioner is covered by information specified in Explanation 1(i) of Section 148 of the IT Act. It is not the case of the petitioner that information disclosed vide notice under Section 148A(b) of the IT Act is not covered by the information specified in Explanation 1(i) of Section 148 of the IT Act. - We respectfully disagree with the judgment of Charu Chains and Jewels Pvt. Ltd. [2023 (1) TMI 486 - DELHI HIGH COURT] - HC
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