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 u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
Addition u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
