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...
Clandestine removal - Invocation of extended period of limitation - It is held that apparently and admittedly appellant was regularly filing the returns. Hence, the facts were regularly brought to the notice of the Department. But there is nothing produced on record by the Department to show any positive act on part of the appellant which may amount to suppression of relevant facts. Resultantly, the demand for a period of more than one year could not have been made - AT
Clandestine removal - Invocation of extended period of limitation - It is held that apparently and admittedly appellant was regularly filing the returns. Hence, the facts were regularly brought to the notice of the Department. But there is nothing produced on record by the Department to show any positive act on part of the appellant which may amount to suppression of relevant facts. Resultantly, the demand for a period of more than one year could not have been made - AT
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