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...
Refund of unutilised cenvat credit of service tax - export of services - the appellant have been receiving foreign inward remittances on their export invoices which were coming to the appellant in terms of JV agreement from a designated bank account specifically opened for the said purpose - the appellant cannot be denied the benefit of export of services simply on the ground that payment has been routed through a 3rd party which is also based outside the country. - AT
Refund of unutilised cenvat credit of service tax - export of services - the appellant have been receiving foreign inward remittances on their export invoices which were coming to the appellant in terms of JV agreement from a designated bank account specifically opened for the said purpose - the appellant cannot be denied the benefit of export of services simply on the ground that payment has been routed through a 3rd party which is also based outside the country. - AT
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