Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Writ interference with a GST show cause notice and adjudication order was declined because an efficacious statutory appeal was available and no breach of natural justice or statutory provision was shown. The petitioner had participated in the proceedings, filed replies, and had not raised before adjudication the plea that only part of the notice was served. The reference to 2021 in the relied-upon documents was accepted as an inadvertent typographical error, as the demand related to October 2018 to November 2019. The order in original covered the relevant periods and showed that the petitioner had sufficient opportunity of hearing; the disputed factual issues were left to the appellate authority.
Writ interference with a GST show cause notice and adjudication order was declined because an efficacious statutory appeal was available and no breach of natural justice or statutory provision was shown. The petitioner had participated in the proceedings, filed replies, and had not raised before adjudication the plea that only part of the notice was served. The reference to 2021 in the relied-upon documents was accepted as an inadvertent typographical error, as the demand related to October 2018 to November 2019. The order in original covered the relevant periods and showed that the petitioner had sufficient opportunity of hearing; the disputed factual issues were left to the appellate authority.
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