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...
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
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