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 amount refunded - Department did not file any appeal against the Order-in-Original granting refund to the appellant which has attained finality and cannot be offset by demand of refund on the ground that it is erroneous.
Recovery of amount refunded - Department did not file any appeal against the Order-in-Original granting refund to the appellant which has attained finality and cannot be offset by demand of refund on the ground that it is erroneous.
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