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...
Transfer of case u/s 127 - proposal for centralization of assessment in a group of cases - Before transferring the case, reasons were not disclosed - Only after raising the objections, post-decisional hearing was provided which is not contemplated under the statute - the decision making process leading to passing of the two impugned orders has been vitiated for non-compliance to the statutory procedural requirements - orders set aside and quashed - HC
Transfer of case u/s 127 - proposal for centralization of assessment in a group of cases - Before transferring the case, reasons were not disclosed - Only after raising the objections, post-decisional hearing was provided which is not contemplated under the statute - the decision making process leading to passing of the two impugned orders has been vitiated for non-compliance to the statutory procedural requirements - orders set aside and quashed - HC
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