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...
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Time-Barred Refund Claim as per Section 11B(1) - Argument of the appellant that a favourable decision taken by the Commissioner with reference to their Gandhar unit should be taken as a deemed protest for the appellants unit is not acceptable as each registered unit is a separate legal entity - AT
Time-Barred Refund Claim as per Section 11B(1) - Argument of the appellant that a favourable decision taken by the Commissioner with reference to their Gandhar unit should be taken as a deemed protest for the appellants unit is not acceptable as each registered unit is a separate legal entity - AT
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