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 - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
Assessment u/s 153A - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
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