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...
Levy of penalty for violation of section 129 and Rule 138 - Failure to update the E-way bill on change of vehicle after breakdown - The imposition of penalties for mere technical errors in tax law, without evidence of intent to evade tax, is not sustainable. The court emphasized that penalties should only be imposed when there's a deliberate intent to evade taxes, differentiating between inadvertent technical errors and purposeful attempts to circumvent tax obligations. - HC
Levy of penalty for violation of section 129 and Rule 138 - Failure to update the E-way bill on change of vehicle after breakdown - The imposition of penalties for mere technical errors in tax law, without evidence of intent to evade tax, is not sustainable. The court emphasized that penalties should only be imposed when there's a deliberate intent to evade taxes, differentiating between inadvertent technical errors and purposeful attempts to circumvent tax obligations. - HC
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