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...
Imposition of a penalty without issuing a show cause notice or affording a hearing breaches the statutory discipline governing penalties and the principles of natural justice. As the revenue did not dispute that no notice initiating penalty proceedings was issued, the High Court found the petitioner had been denied the required opportunity to respond. The penalty was therefore unsustainable, and the writ petition was disposed of accordingly.
Imposition of a penalty without issuing a show cause notice or affording a hearing breaches the statutory discipline governing penalties and the principles of natural justice. As the revenue did not dispute that no notice initiating penalty proceedings was issued, the High Court found the petitioner had been denied the required opportunity to respond. The penalty was therefore unsustainable, and the writ petition was disposed of accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
