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...
Valuation of exported CD ROMS - Import of goods by availing excess export promotion benefits i.e. DEBP/DEEC Credits - The Tribunal notes that the DEPB licenses issued to the Respondents were not canceled by the DGFT, indicating their validity. After thorough examination, the Tribunal concludes that the disputed matter is settled in favor of the Respondents based on previous judgments and the lack of valid grounds for the Revenue's claims. It upholds the impugned orders and dismisses the appeals filed by the Revenue.
Valuation of exported CD ROMS - Import of goods by availing excess export promotion benefits i.e. DEBP/DEEC Credits - The Tribunal notes that the DEPB licenses issued to the Respondents were not canceled by the DGFT, indicating their validity. After thorough examination, the Tribunal concludes that the disputed matter is settled in favor of the Respondents based on previous judgments and the lack of valid grounds for the Revenue's claims. It upholds the impugned orders and dismisses the appeals filed by the Revenue.
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