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...
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
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