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...
Validity of rejection of Advance Ruling application - application rejected without due opportunity to show cause against the reason assigned - The petition is allowed in part, and the respondent’s order dated 29.11.2022 [Annexure-A] rejecting the petitioner's application for advance ruling without admitting it for detailed consideration is quashed and the application is restored for reconsideration with due opportunity to the petitioner. - HC
Validity of rejection of Advance Ruling application - application rejected without due opportunity to show cause against the reason assigned - The petition is allowed in part, and the respondent’s order dated 29.11.2022 [Annexure-A] rejecting the petitioner's application for advance ruling without admitting it for detailed consideration is quashed and the application is restored for reconsideration with due opportunity to the petitioner. - HC
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