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...
An Assessing Officer who is bound by earlier remand directions must adjudicate the original show cause notice after granting personal hearing and considering the reply; issuing a second show cause notice instead is treated as impermissible overreaching of the prior court order. The note states that the impugned adjudication was set aside and the matter remanded for fresh decision on the first show cause notice in compliance with natural justice under Section 75(4).
An Assessing Officer who is bound by earlier remand directions must adjudicate the original show cause notice after granting personal hearing and considering the reply; issuing a second show cause notice instead is treated as impermissible overreaching of the prior court order. The note states that the impugned adjudication was set aside and the matter remanded for fresh decision on the first show cause notice in compliance with natural justice under Section 75(4).
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