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...
Refund claim - Unjust enrichment - barring an amount of ₹ 3 lakhs, the appellant themselves were admitting that the remaining amount has been recovered from their customers. Even the amount of ₹ 3 lakhs which according to them has been paid by from their own resources cannot be considered for refund as the doctrine of unjust enrichment would be applicable at this stage - AT
Refund claim - Unjust enrichment - barring an amount of ₹ 3 lakhs, the appellant themselves were admitting that the remaining amount has been recovered from their customers. Even the amount of ₹ 3 lakhs which according to them has been paid by from their own resources cannot be considered for refund as the doctrine of unjust enrichment would be applicable at this stage - AT
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