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...
Waiver or exemption provisions require strict compliance with substantive conditions, while substantial compliance may satisfy procedural requirements. Where the full GST liability was paid within the stipulated period but credited under an incorrect tax head because of an uncontroverted clerical error, payment was treated as substantially compliant. The High Court set aside the rejection of the waiver application and remanded it for fresh consideration after a reasonable opportunity, requiring the payment to be credited under the appropriate CGST and SGST heads.
Waiver or exemption provisions require strict compliance with substantive conditions, while substantial compliance may satisfy procedural requirements. Where the full GST liability was paid within the stipulated period but credited under an incorrect tax head because of an uncontroverted clerical error, payment was treated as substantially compliant. The High Court set aside the rejection of the waiver application and remanded it for fresh consideration after a reasonable opportunity, requiring the payment to be credited under the appropriate CGST and SGST heads.
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