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...
Condonation of delay in filing appeal before the Commissioner (Appeals) - Dismissal of appeal on the ground that the appeal was delayed by thirty three days - exclusion of the period during which the matter was pending before the High Court. - The Supreme court found merit in the appellant's argument and held that the delay in filing the appeal should be condoned under the proviso to sub-section 3A of Section 85 of the Finance Act, 1994. Consequently, the impugned orders were set aside, and the matter was restored to the file of the Commissioner (Appeals)
Condonation of delay in filing appeal before the Commissioner (Appeals) - Dismissal of appeal on the ground that the appeal was delayed by thirty three days - exclusion of the period during which the matter was pending before the High Court. - The Supreme court found merit in the appellant's argument and held that the delay in filing the appeal should be condoned under the proviso to sub-section 3A of Section 85 of the Finance Act, 1994. Consequently, the impugned orders were set aside, and the matter was restored to the file of the Commissioner (Appeals)
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