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...
Recovery of redemption fine from the petitioner - petitioner was not party to the SCN - In absence of any proposal in the show cause notice for imposition of fine in lieu of confiscation relatable to the petitioner and in absence of any directions contained in the order-inoriginal that such fine would be borne by the petitioner, it was simply not open for the department to seek recovery thereof from the petitioner- HC
Recovery of redemption fine from the petitioner - petitioner was not party to the SCN - In absence of any proposal in the show cause notice for imposition of fine in lieu of confiscation relatable to the petitioner and in absence of any directions contained in the order-inoriginal that such fine would be borne by the petitioner, it was simply not open for the department to seek recovery thereof from the petitioner- HC
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