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...
Refund of service tax paid - delay in filing refund claim - time limitation - it is found that the appellant was confused in so far as they believed that the refund is to be filed on quarterly basis and therefore, they counted the delay on the basis of the last date of the quarter. If the last date of filing the refund is taken as the end of the quarter then the refund claims have been filed in time. There is a reasonable cause and in this circumstances the discretion are in favor of the appellant. - AT
Refund of service tax paid - delay in filing refund claim - time limitation - it is found that the appellant was confused in so far as they believed that the refund is to be filed on quarterly basis and therefore, they counted the delay on the basis of the last date of the quarter. If the last date of filing the refund is taken as the end of the quarter then the refund claims have been filed in time. There is a reasonable cause and in this circumstances the discretion are in favor of the appellant. - AT
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