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 order passed by the Tribunal (ITAT) - Non issuance or service of notice to the appellant for hearing - Mere dispatch of a notice is not sufficient. To hold that notice came to the knowledge of the petitioner, the notice should also have been received by the person/assessee to whom it was addressed. There are no records to show the notice of intimation was received by the petitioner. - HC
Validity of order passed by the Tribunal (ITAT) - Non issuance or service of notice to the appellant for hearing - Mere dispatch of a notice is not sufficient. To hold that notice came to the knowledge of the petitioner, the notice should also have been received by the person/assessee to whom it was addressed. There are no records to show the notice of intimation was received by the petitioner. - HC
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