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...
Jurisdiction of Inspection u/s 67 and collection of collected records/documents - Existence of reasons to believe - Necessarily the contentions of the petitioner as raised in this writ petition including questioning the jurisdiction of the second respondent to issue the intimation letters all dated 07.01.2023 has to be decided by the third respondent before passing final orders after affording an opportunity of personal hearing to the petitioner and also considering their reply, which they propose to send in due course - HC
Jurisdiction of Inspection u/s 67 and collection of collected records/documents - Existence of reasons to believe - Necessarily the contentions of the petitioner as raised in this writ petition including questioning the jurisdiction of the second respondent to issue the intimation letters all dated 07.01.2023 has to be decided by the third respondent before passing final orders after affording an opportunity of personal hearing to the petitioner and also considering their reply, which they propose to send in due course - HC
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