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...
Revenue receipt or capital receipt - Foreign exchange gain written back on cancellation of vessel construction contract taxed u/s. 28(iv) - The ITAT agreed with the assessee, holding that the gain was a capital receipt not taxable under Section 28(iv) of the Act. This decision underscores the differentiation between capital and revenue receipts, particularly in the context of foreign exchange gains related to capital assets.
Revenue receipt or capital receipt - Foreign exchange gain written back on cancellation of vessel construction contract taxed u/s. 28(iv) - The ITAT agreed with the assessee, holding that the gain was a capital receipt not taxable under Section 28(iv) of the Act. This decision underscores the differentiation between capital and revenue receipts, particularly in the context of foreign exchange gains related to capital assets.
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