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 u/s 73 - non willful mis-statement - discrepancies found on the returns - Validity of notice uploaded in the common portal and not communicated physically - The High court acknowledged the petitioner's assertion that they possess the necessary documents to refute the alleged discrepancies and are willing to submit them. - The court allowed the writ petition, setting aside the impugned order. The matter was remanded back to the respondent for fresh consideration. The petitioner was directed to appear before the respondent with the required documents on a specified date, and the respondent was instructed to reconsider the issue promptly.
Levy of Penalty u/s 73 - non willful mis-statement - discrepancies found on the returns - Validity of notice uploaded in the common portal and not communicated physically - The High court acknowledged the petitioner's assertion that they possess the necessary documents to refute the alleged discrepancies and are willing to submit them. - The court allowed the writ petition, setting aside the impugned order. The matter was remanded back to the respondent for fresh consideration. The petitioner was directed to appear before the respondent with the required documents on a specified date, and the respondent was instructed to reconsider the issue promptly.
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