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...
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Offence punishable u/s 276C(2) - In the present case, the allegations in both the proceedings are similar - demand raised by the Department is not crystallized as the appeal preferred by the petitioner is pending adjudication on merits.Since the petitioner has already deposited a substantial part of the demand raised by the Department, this Court is of the opinion that the continuation of the prosecution against the petitioner for the same allegations could not be permitted. - Prosecution proceedings stayed - HC
Offence punishable u/s 276C(2) - In the present case, the allegations in both the proceedings are similar - demand raised by the Department is not crystallized as the appeal preferred by the petitioner is pending adjudication on merits.Since the petitioner has already deposited a substantial part of the demand raised by the Department, this Court is of the opinion that the continuation of the prosecution against the petitioner for the same allegations could not be permitted. - Prosecution proceedings stayed - HC
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