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...
Application for admission of additional grounds - Challenging the Jurisdiction - proper officer to issue SCN - Amendments made by the Finance Act, 2022 - by the Act, the actions taken have been validated by the will of Parliament. Hence the decisions rendered contrary to the express intent of Section 97 is per incuriam. - Application dismissed - AT
Application for admission of additional grounds - Challenging the Jurisdiction - proper officer to issue SCN - Amendments made by the Finance Act, 2022 - by the Act, the actions taken have been validated by the will of Parliament. Hence the decisions rendered contrary to the express intent of Section 97 is per incuriam. - Application dismissed - AT
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