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...
Addition u/s 68 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
Addition u/s 68 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
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