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...
Job-work - benefit of N/N. 214/96 and N/N. 84/95-CE cannot be extended to the appellant as the requisite undertakings have not been given by the appellant - These undertakings are not merely procedural undertaking but substantive undertaking in so far as by virtue of this undertaking, the principal manufacturer takes the responsibility of duty liability in case it arose - AT
Job-work - benefit of N/N. 214/96 and N/N. 84/95-CE cannot be extended to the appellant as the requisite undertakings have not been given by the appellant - These undertakings are not merely procedural undertaking but substantive undertaking in so far as by virtue of this undertaking, the principal manufacturer takes the responsibility of duty liability in case it arose - AT
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