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 High Court held that cash incentives accrue to the assessee on the date when the application for claim is submitted to the Competent Authority, and not from the date of actual receipt or disbursement of the incentive. This view aligns with the court's earlier decision in a similar case. The reference was decided in favor of the assessee and against the Revenue authorities regarding the timing of accrual recognition for cash incentives.
The High Court held that cash incentives accrue to the assessee on the date when the application for claim is submitted to the Competent Authority, and not from the date of actual receipt or disbursement of the incentive. This view aligns with the court's earlier decision in a similar case. The reference was decided in favor of the assessee and against the Revenue authorities regarding the timing of accrual recognition for cash incentives.
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