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...
Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.
Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.
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