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...
The ITAT Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
The ITAT Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
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