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...
Validity of assessment - show cause notice has been issued manually - The petitioner refers to a snap shot of the E-portal contending that does not refer to show cause notice dated 20.05.2019. This would, at best, amount to a technical error and will not vitiate the assessment itself for the reason that the show cause notice has been manually issued and proof of service of the same is also available on record. - The challenge to the assessment thus fails - HC
Validity of assessment - show cause notice has been issued manually - The petitioner refers to a snap shot of the E-portal contending that does not refer to show cause notice dated 20.05.2019. This would, at best, amount to a technical error and will not vitiate the assessment itself for the reason that the show cause notice has been manually issued and proof of service of the same is also available on record. - The challenge to the assessment thus fails - HC
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