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 to the book profit u/s 115JB for the amount disallowed u/s 14A r.w. Rule 8D - the tribunal noted that the AO had made the disallowance under Section 14A, but the assessee hadn't adjusted this amount while computing the book profit. The tribunal upheld the addition to the book profit, affirming the decision of the CIT(A) and partly allowing the Revenue's appeal on this ground.
Addition to the book profit u/s 115JB for the amount disallowed u/s 14A r.w. Rule 8D - the tribunal noted that the AO had made the disallowance under Section 14A, but the assessee hadn't adjusted this amount while computing the book profit. The tribunal upheld the addition to the book profit, affirming the decision of the CIT(A) and partly allowing the Revenue's appeal on this ground.
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