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...
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
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