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...
Violation of principles of natural justice - Validity of assessment order - As adverse orders would have been passed against the petitioner, it was incumbent on the part of the respondents to issue a notice of personal hearing to the petitioner. Though in this case, admittedly the petitioner had filed the reply belatedly on 16.08.2021 having considered the reply and having decided to pass an adverse order, it was incumbent on the part of the respondents to call upon the petitioner for a personal hearing. - Matter restored back - HC
Violation of principles of natural justice - Validity of assessment order - As adverse orders would have been passed against the petitioner, it was incumbent on the part of the respondents to issue a notice of personal hearing to the petitioner. Though in this case, admittedly the petitioner had filed the reply belatedly on 16.08.2021 having considered the reply and having decided to pass an adverse order, it was incumbent on the part of the respondents to call upon the petitioner for a personal hearing. - Matter restored back - HC
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