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...
Best judgment assessment - The assertion of the learned counsel that Form 26AS can be provided only by the Income Tax department to the Central Excise officers is not correct. The assessee himself could have provided this form to the central excise department as well - the assessee’s objections to best judgment assessment in the impugned order has no legs to stand on and deserves to be dismissed. - AT
Best judgment assessment - The assertion of the learned counsel that Form 26AS can be provided only by the Income Tax department to the Central Excise officers is not correct. The assessee himself could have provided this form to the central excise department as well - the assessee’s objections to best judgment assessment in the impugned order has no legs to stand on and deserves to be dismissed. - AT
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