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 u/s 14A - disallowance of administrative expenditure to arrive at average total asset for computing disallowance as per formula prescribed by Rule 8D on the opening and closing of gross block of fixed assets - Validity of order of ITAT remanding the matter to the AO for proper verification and adjudication - The High Court acknowledged previous decisions and directed the matter to be remanded to the Tribunal for fresh consideration regarding the disputed grounds.
Disallowance u/s 14A - disallowance of administrative expenditure to arrive at average total asset for computing disallowance as per formula prescribed by Rule 8D on the opening and closing of gross block of fixed assets - Validity of order of ITAT remanding the matter to the AO for proper verification and adjudication - The High Court acknowledged previous decisions and directed the matter to be remanded to the Tribunal for fresh consideration regarding the disputed grounds.
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