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...
Estimation of income - bogus purchases - The ITAT found the CIT(A)'s decision to restrict the addition to a percentage of disputed purchases as a reasonable estimation. It was noted that without knowing the parties to whom the diamonds were sold, the onus of proving the genuineness of transactions was not fully discharged by the assessee. The ITAT upheld the CIT(A)'s approach as justified and dismissed the Revenue's appeal and the assessee's cross-objection.
Estimation of income - bogus purchases - The ITAT found the CIT(A)'s decision to restrict the addition to a percentage of disputed purchases as a reasonable estimation. It was noted that without knowing the parties to whom the diamonds were sold, the onus of proving the genuineness of transactions was not fully discharged by the assessee. The ITAT upheld the CIT(A)'s approach as justified and dismissed the Revenue's appeal and the assessee's cross-objection.
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