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...
Consistent treatment of identical export services is central to refund eligibility for unutilised input tax credit on zero-rated supplies. The note states that services granted refunds in periods before and after the disputed period should not be classified as intermediary services for the intervening period without material distinguishing their nature. Such differential classification is described as arbitrary, discriminatory and contrary to the principle of consistency. It records that rejection of the refund claim was set aside and release of the refund with applicable interest was directed.
Consistent treatment of identical export services is central to refund eligibility for unutilised input tax credit on zero-rated supplies. The note states that services granted refunds in periods before and after the disputed period should not be classified as intermediary services for the intervening period without material distinguishing their nature. Such differential classification is described as arbitrary, discriminatory and contrary to the principle of consistency. It records that rejection of the refund claim was set aside and release of the refund with applicable interest was directed.
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