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 - carry forward of excess credit - it was a bona fide mistake of carrying forward excess credit - There is no other allegation or evidence brought on record by the revenue that intentionally and purposefully the Appellant had shown wrong opening balance thereby continued to enjoy excess credit for a period of time till it is pointed out by the audit. Therefore, imposition of penalty equal to the amount of credit availed cannot be sustained. - AT
Levy of penalty - carry forward of excess credit - it was a bona fide mistake of carrying forward excess credit - There is no other allegation or evidence brought on record by the revenue that intentionally and purposefully the Appellant had shown wrong opening balance thereby continued to enjoy excess credit for a period of time till it is pointed out by the audit. Therefore, imposition of penalty equal to the amount of credit availed cannot be sustained. - AT
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