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...
Levy of penalty - ITC wrongly availed - As such, if the respondent was of the view that the claim of ITC has been wrongly made, the only option available is to reverse such an ITC instead of bringing them under the purview of Section 7(1)(a) of the TNVAT Act. As such, the levy of tax under Section 7(1)(b) and the consequential penalty imposed, cannot be sustained. - HC
Levy of penalty - ITC wrongly availed - As such, if the respondent was of the view that the claim of ITC has been wrongly made, the only option available is to reverse such an ITC instead of bringing them under the purview of Section 7(1)(a) of the TNVAT Act. As such, the levy of tax under Section 7(1)(b) and the consequential penalty imposed, cannot be sustained. - HC
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