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...
Scope of SCN - vague SCN - absence of specific demand of service tax under a particular service - The Tribunal held that the defect in the notice cannot be cured by the observations of the adjudicating authority or appellate authority. Accordingly, the demand of service tax along with interest and penalty confirmed in the impugned order is not sustainable as the SCN fails to specify the category of service under which the demand has been raised.
Scope of SCN - vague SCN - absence of specific demand of service tax under a particular service - The Tribunal held that the defect in the notice cannot be cured by the observations of the adjudicating authority or appellate authority. Accordingly, the demand of service tax along with interest and penalty confirmed in the impugned order is not sustainable as the SCN fails to specify the category of service under which the demand has been raised.
Note: It is a system-generated summary and is for quick reference only.