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 an appeal before the Appellate Authority - The High Court, while acknowledging the delay in appeal filing beyond the condonable period of limitation, emphasized the petitioner's substantive right to seek redress. Considering that the tax liability had already been recovered from the petitioner and a pre-deposit was made along with the appeal, the court directed the second respondent to consider and decide on the appeal without considering the limitation period. As a result, the writ petition was allowed, with no costs incurred.
Condonation of delay in filing an appeal before the Appellate Authority - The High Court, while acknowledging the delay in appeal filing beyond the condonable period of limitation, emphasized the petitioner's substantive right to seek redress. Considering that the tax liability had already been recovered from the petitioner and a pre-deposit was made along with the appeal, the court directed the second respondent to consider and decide on the appeal without considering the limitation period. As a result, the writ petition was allowed, with no costs incurred.
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