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...
Seeking refund of amount paid under threat or duress in pursuance of an investigation - Though the original issuance of the show-cause notice may be in terms of the directions of the writ Court, any further contemplation of proceeding with the show-cause notice, would be without any authority, in view of the subsequent order passed. Thus, the consequential notice could be termed to be without any jurisdiction and would amount to an abuse of the process of law - Refund allowed - HC
Seeking refund of amount paid under threat or duress in pursuance of an investigation - Though the original issuance of the show-cause notice may be in terms of the directions of the writ Court, any further contemplation of proceeding with the show-cause notice, would be without any authority, in view of the subsequent order passed. Thus, the consequential notice could be termed to be without any jurisdiction and would amount to an abuse of the process of law - Refund allowed - HC
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