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...
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Non acceptance of fresh evidence submitted u/r 46A of the I. T. Rules by CIT(A) - Tribunal noted that, it is possible that in the transition, the ld.CIT(A)[NFAC] had not received copies of the additional evidence filed by assessee. - Consequently, the Tribunal held that, as the Faceless Appeal was a new concept to CIT(A) as well as Assessee, the error which has crept is a possible human error and restored the matter to ld.CIT(A) for denovo adjudication.
Non acceptance of fresh evidence submitted u/r 46A of the I. T. Rules by CIT(A) - Tribunal noted that, it is possible that in the transition, the ld.CIT(A)[NFAC] had not received copies of the additional evidence filed by assessee. - Consequently, the Tribunal held that, as the Faceless Appeal was a new concept to CIT(A) as well as Assessee, the error which has crept is a possible human error and restored the matter to ld.CIT(A) for denovo adjudication.
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