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...
Deduction for gratuity actually paid under section 43B was allowed because the assessee substantiated actual payment with audited financial statements, actuarial provision entries, profit and loss account debit, gratuity disclosures, and supporting ledger and salary records. The Tribunal held that the evidentiary record proved payment to the relevant employees and that the disallowance based on alleged absence of proof was factually unsustainable. The deletion of the disallowance was therefore upheld and the claim for deduction was allowed.
Deduction for gratuity actually paid under section 43B was allowed because the assessee substantiated actual payment with audited financial statements, actuarial provision entries, profit and loss account debit, gratuity disclosures, and supporting ledger and salary records. The Tribunal held that the evidentiary record proved payment to the relevant employees and that the disallowance based on alleged absence of proof was factually unsustainable. The deletion of the disallowance was therefore upheld and the claim for deduction was allowed.
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