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...
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
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