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...
Maintainability of application for Advance Ruling - The AAR while dismissing the application held that, in the instant case, the questions, on which the applicant seeks advance ruling, are not in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the said applicant, but in relation to a completed supply on which self-assessed tax is discharged by the applicant. Therefore, the instant application is beyond the jurisdiction of this authority and hence is liable for rejection.
Maintainability of application for Advance Ruling - The AAR while dismissing the application held that, in the instant case, the questions, on which the applicant seeks advance ruling, are not in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the said applicant, but in relation to a completed supply on which self-assessed tax is discharged by the applicant. Therefore, the instant application is beyond the jurisdiction of this authority and hence is liable for rejection.
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