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...
Condonation of delay in filing appeal - rejection of appeal on the ground of time bar - Heavy burden lies on such appellant to explain the delay sufficiently, for each day. The explanation on ground of illness, given by appellant is held to be absolutely vague in the present case as the appellant could not substantiate with any medical record. Hence, possibility of appeal filed before Commissioner (Appeals) to be an afterthought and a time gaining strategy cannot be ruled out. - AT
Condonation of delay in filing appeal - rejection of appeal on the ground of time bar - Heavy burden lies on such appellant to explain the delay sufficiently, for each day. The explanation on ground of illness, given by appellant is held to be absolutely vague in the present case as the appellant could not substantiate with any medical record. Hence, possibility of appeal filed before Commissioner (Appeals) to be an afterthought and a time gaining strategy cannot be ruled out. - AT
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