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...
Deposits made by assessee in Krishi Bank were fixed deposit investments, not trading activity. Loss suffered when bank went into liquidation is capital loss, not business loss u/s 28 or bad debt u/s 36(1)(vii). Assessing Officer and appellate authorities rightly treated loss as capital loss based on evidence. No substantial question of law arises for adjudication u/s 260A as it involves findings of fact which cannot be re-adjudicated in appeal. Substantial question of law answered against assessee in favor of revenue.
Deposits made by assessee in Krishi Bank were fixed deposit investments, not trading activity. Loss suffered when bank went into liquidation is capital loss, not business loss u/s 28 or bad debt u/s 36(1)(vii). Assessing Officer and appellate authorities rightly treated loss as capital loss based on evidence. No substantial question of law arises for adjudication u/s 260A as it involves findings of fact which cannot be re-adjudicated in appeal. Substantial question of law answered against assessee in favor of revenue.
Note: It is a system-generated summary and is for quick reference only.