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...
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Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
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