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...
Settlement of a Case - Procedure u/s 245D - Non deposit of admitted tax u/s 245C on time - Payment of the taxes of additional income partly by way of adjustment against cash seized. - On receiving notice, petitioner paid the amount through challan and placed the same on file - The confusion and the error, if at all, arises only from the contents of letter dated 17.12.2018. The unambiguous impression that it conveys is that the entirety of the credit determined as balance in the PD account enured to the benefit of this petitioner. - Settlement application stands restored - HC
Settlement of a Case - Procedure u/s 245D - Non deposit of admitted tax u/s 245C on time - Payment of the taxes of additional income partly by way of adjustment against cash seized. - On receiving notice, petitioner paid the amount through challan and placed the same on file - The confusion and the error, if at all, arises only from the contents of letter dated 17.12.2018. The unambiguous impression that it conveys is that the entirety of the credit determined as balance in the PD account enured to the benefit of this petitioner. - Settlement application stands restored - HC
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