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...
Rectification u/s 154 - AO had not suo-moto initiated rectification proceedings but acted on the application of the assessee - As the Assessing Officer acted upon the rectification applications and reduced the liability of the assessee, the appeals were dismissed as the assessee did not demonstrate any grievance with the 154 order.
Rectification u/s 154 - AO had not suo-moto initiated rectification proceedings but acted on the application of the assessee - As the Assessing Officer acted upon the rectification applications and reduced the liability of the assessee, the appeals were dismissed as the assessee did not demonstrate any grievance with the 154 order.
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