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...
Apprehension of pre-judging the matter - Validity of preliminary report - the challenge to the preliminary report dated 02.06.2023 has worked itself out inasmuch as subsequently a final report has been drawn on 24.07.2023 and the correctness of the said report also need not be gone into at this juncture since the matter has now travelled to the stage of issuance of the show cause notice dated 23.08.2023. - HC
Apprehension of pre-judging the matter - Validity of preliminary report - the challenge to the preliminary report dated 02.06.2023 has worked itself out inasmuch as subsequently a final report has been drawn on 24.07.2023 and the correctness of the said report also need not be gone into at this juncture since the matter has now travelled to the stage of issuance of the show cause notice dated 23.08.2023. - HC
Note: It is a system-generated summary and is for quick reference only.