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 order rejecting a rebate claim and imposing penalty, based exclusively on a prior Single Judge decision, could not stand after that precedent was later set aside by a Division Bench. The High Court quashed the order because its sole foundation had disappeared, and remanded the rebate and penalty issues to the competent authority for fresh consideration in light of the Division Bench view, without expressing any opinion on merits.
An order rejecting a rebate claim and imposing penalty, based exclusively on a prior Single Judge decision, could not stand after that precedent was later set aside by a Division Bench. The High Court quashed the order because its sole foundation had disappeared, and remanded the rebate and penalty issues to the competent authority for fresh consideration in light of the Division Bench view, without expressing any opinion on merits.
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