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...
Invokation of Section 80 of the Finance Act, 1994 and immunity from penalty under Section 78 of the Act - Levy of service tax being an indirect tax mechanism hardship is faced by the tax payer if incidence of tax is not realised from the service recipient. Considering such aspect and taking into consideration that a part of the penalty amount has been discharged, the balance of the penalty is waived. - AT
Invokation of Section 80 of the Finance Act, 1994 and immunity from penalty under Section 78 of the Act - Levy of service tax being an indirect tax mechanism hardship is faced by the tax payer if incidence of tax is not realised from the service recipient. Considering such aspect and taking into consideration that a part of the penalty amount has been discharged, the balance of the penalty is waived. - AT
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