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...
Advance ruling jurisdiction is confined to questions enumerated for advance rulings; refund eligibility and computation of accumulated input tax credit under the inverted duty structure were treated as outside that scope. The text also notes that where the same refund question has already been decided in proceedings under the Act, admission is barred. On that basis, the application was rejected as not maintainable.
Advance ruling jurisdiction is confined to questions enumerated for advance rulings; refund eligibility and computation of accumulated input tax credit under the inverted duty structure were treated as outside that scope. The text also notes that where the same refund question has already been decided in proceedings under the Act, admission is barred. On that basis, the application was rejected as not maintainable.
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