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...
Validity of draft assessment order and final assessment order as barred by limitation u/s 153(2A) - Scope of the word “received” - Tribunal held the draft assessment order and final assessment order passed by the AO are barred by limitation u/s 153(2A) - The High Court observed that, ITAT has while passing the orders impugned before us proceeded on the basis of the principles enunciated in the aforenoted two decisions of the High Court. - The HC dismissed the revenue's appeal.
Validity of draft assessment order and final assessment order as barred by limitation u/s 153(2A) - Scope of the word “received” - Tribunal held the draft assessment order and final assessment order passed by the AO are barred by limitation u/s 153(2A) - The High Court observed that, ITAT has while passing the orders impugned before us proceeded on the basis of the principles enunciated in the aforenoted two decisions of the High Court. - The HC dismissed the revenue's appeal.
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