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...
Penalty u/s 271D & 271E - default committed in violation of section 269SS & 269T - Reliance on search proceeding documents - Transactions being mere book entries - Following the judgement of Supreme Court, the Tribunal held that, the expression “money” means currency/cash. Therefore, very essential ingredient to constitute a default within the meaning of 269SS or 269T is that whether there is movement of money. Mere book entries alone, during the course of training, cannot entail a default of taking or repaying the loan in cash, unless it is established that Moneys moved from one person to another person, which is in the nature of loans or deposits” - CIT(A) rightly deleted the penalties.
Penalty u/s 271D & 271E - default committed in violation of section 269SS & 269T - Reliance on search proceeding documents - Transactions being mere book entries - Following the judgement of Supreme Court, the Tribunal held that, the expression “money” means currency/cash. Therefore, very essential ingredient to constitute a default within the meaning of 269SS or 269T is that whether there is movement of money. Mere book entries alone, during the course of training, cannot entail a default of taking or repaying the loan in cash, unless it is established that Moneys moved from one person to another person, which is in the nature of loans or deposits” - CIT(A) rightly deleted the penalties.
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