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...
Levy of penalty u/s 112 (a) & (b) (iii) and 114A of the Customs Act, 1962 - importing rough precious stones by making huge overvaluation - goods not imported by actual importers but the imports are being managed by someone else behind them - it is clear that the appellant has deliberately and intentionally has not provided any such information which was false or incorrect. As such, in my opinion that penalty under section 114AA of the Customs Act, 1962 has wrongly been imposed upon him. - AT
Levy of penalty u/s 112 (a) & (b) (iii) and 114A of the Customs Act, 1962 - importing rough precious stones by making huge overvaluation - goods not imported by actual importers but the imports are being managed by someone else behind them - it is clear that the appellant has deliberately and intentionally has not provided any such information which was false or incorrect. As such, in my opinion that penalty under section 114AA of the Customs Act, 1962 has wrongly been imposed upon him. - AT
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