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...
Unexplained investment u/s 69 - The tribunal closely examined the additions made under Section 69 related to unexplained investments in stock. The assessees argued that rough jottings or documents seized during raids were not conclusive evidence of unaccounted investments. Furthermore, they contended that previous voluntary disclosures or surrendered amounts during surveys should offset these additions.
Unexplained investment u/s 69 - The tribunal closely examined the additions made under Section 69 related to unexplained investments in stock. The assessees argued that rough jottings or documents seized during raids were not conclusive evidence of unaccounted investments. Furthermore, they contended that previous voluntary disclosures or surrendered amounts during surveys should offset these additions.
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