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...
Order of transfer u/s 127 - transferring the case of the petitioner from Raipur to Delhi - Even if financial nexus is not palpable between the petitioner and the searched party, that by itself cannot take away the right of the Revenue to exercise its wide and sweeping powers u/s 127 of transferring a case in public interest i.e. for effective and expeditious completion of search, seizure and other operations. of premises. - HC
Order of transfer u/s 127 - transferring the case of the petitioner from Raipur to Delhi - Even if financial nexus is not palpable between the petitioner and the searched party, that by itself cannot take away the right of the Revenue to exercise its wide and sweeping powers u/s 127 of transferring a case in public interest i.e. for effective and expeditious completion of search, seizure and other operations. of premises. - HC
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