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...
Rejection of SVLDR scheme - it is clear that any investigation pertaining to the period from 2014 to 2016 by the authorities should not affect the declarations made by the petitioner in respect of the period from April, 2016 onwards. The contention of the respondents (Revenue) is that the investigation pertains to the period 2016–17 also and the respondents are yet to quantify and communicate the amount due. - . The Designated Committee is directed to decide the petitioner’s applications/declarations after giving an opportunity of hearing to the petitioner - HC
Rejection of SVLDR scheme - it is clear that any investigation pertaining to the period from 2014 to 2016 by the authorities should not affect the declarations made by the petitioner in respect of the period from April, 2016 onwards. The contention of the respondents (Revenue) is that the investigation pertains to the period 2016–17 also and the respondents are yet to quantify and communicate the amount due. - . The Designated Committee is directed to decide the petitioner’s applications/declarations after giving an opportunity of hearing to the petitioner - HC
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