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 on Director of the company - The appellant being a Director of the Company involved in the entire Modus Operandi of fraudulent availment of credit and evasion of Excise Duty on the clandestine removal of finished goods. Without the knowledge of the director it could not have been possible to make such a huge evasion of duty. Therefore, the involvement of the director is clearly established. - AT
Levy of penalty on Director of the company - The appellant being a Director of the Company involved in the entire Modus Operandi of fraudulent availment of credit and evasion of Excise Duty on the clandestine removal of finished goods. Without the knowledge of the director it could not have been possible to make such a huge evasion of duty. Therefore, the involvement of the director is clearly established. - AT
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