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...
Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the admissions made during the survey. They referenced section 147 and noted that reassessment was justified based on the prima facie evidence available from the survey. - The tribunal concluded that the notices under section 148 were correctly issued, considering the sworn statements and other corroborating material from the survey, such as the admission of bogus purchases.
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