Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Use of AI-generated legal material in quasi-judicial orders requires independent verification, human oversight, and the issuing officer's own application of mind. Reliance on non-existent or irrelevant AI-generated precedents prompted an unconditional apology, and non-compliance with departmental safeguards was directed to be treated as contempt of court. GST registration cancellation proceedings were quashed because the authorities proposed to revise the challenged orders and issue a fresh notice. Fresh adjudication must consider the taxpayer's reply and defence and result in a reasoned order in accordance with law; the merits remain open.
Use of AI-generated legal material in quasi-judicial orders requires independent verification, human oversight, and the issuing officer's own application of mind. Reliance on non-existent or irrelevant AI-generated precedents prompted an unconditional apology, and non-compliance with departmental safeguards was directed to be treated as contempt of court. GST registration cancellation proceedings were quashed because the authorities proposed to revise the challenged orders and issue a fresh notice. Fresh adjudication must consider the taxpayer's reply and defence and result in a reasoned order in accordance with law; the merits remain open.
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