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...
Post-export amendment of shipping bills to change the scheme code from drawback to RoSCTL was treated as permissible under Section 149, because the three-month limit in Circular No. 36/2010 was not supported by valid law. The text notes that time limits for such amendments could be prescribed only through regulations under Section 157, and that later 2025 regulations reinforced that position. On that basis, the adjudicating authority's decision allowing the amendment was upheld and the Revenue's challenge was rejected.
Post-export amendment of shipping bills to change the scheme code from drawback to RoSCTL was treated as permissible under Section 149, because the three-month limit in Circular No. 36/2010 was not supported by valid law. The text notes that time limits for such amendments could be prescribed only through regulations under Section 157, and that later 2025 regulations reinforced that position. On that basis, the adjudicating authority's decision allowing the amendment was upheld and the Revenue's challenge was rejected.
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