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...
The final decision in this case by the Odisha Appellate Authority for Advance Ruling (AAAR) was set aside due to procedural irregularities and violation of principles of natural justice. The AAAR's order, which reversed the initial ruling of the Authority for Advance Ruling (AAR), was based on a report that was not disclosed to the petitioner, denying them a fair opportunity to respond. The case was remitted back to the AAAR for a fresh decision, ensuring adherence to the principles of natural justice. - High Court
The final decision in this case by the Odisha Appellate Authority for Advance Ruling (AAAR) was set aside due to procedural irregularities and violation of principles of natural justice. The AAAR's order, which reversed the initial ruling of the Authority for Advance Ruling (AAR), was based on a report that was not disclosed to the petitioner, denying them a fair opportunity to respond. The case was remitted back to the AAAR for a fresh decision, ensuring adherence to the principles of natural justice. - High Court
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