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...
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Assessment u/s 153A - completed assessments to be interfered with by the A.O. while making the assessment u/s 153A - The Tribunal upheld the decision of the Ld. CIT(A) in deleting the addition. - The ITAT reiterated the principle that completed assessments can only be interfered with by the AO under Section 153A based on incriminating material found during the search. Since the revenue failed to demonstrate that the additions were made on such basis, the court found no reason to interfere with the order of the Ld. CIT(A).
Assessment u/s 153A - completed assessments to be interfered with by the A.O. while making the assessment u/s 153A - The Tribunal upheld the decision of the Ld. CIT(A) in deleting the addition. - The ITAT reiterated the principle that completed assessments can only be interfered with by the AO under Section 153A based on incriminating material found during the search. Since the revenue failed to demonstrate that the additions were made on such basis, the court found no reason to interfere with the order of the Ld. CIT(A).
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