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...
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
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