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...
Order set aside for violation of principles of natural justice by denying petitioner opportunity of oral hearing before passing adverse assessment order raising excess demand. Assessing Authority mandated to afford such opportunity irrespective of petitioner's choice. In assessment orders creating heavy civil liability, granting minimal hearing opportunity essential. Matter remitted to issue fresh notice to petitioner within two weeks for hearing before passing fresh order.
Order set aside for violation of principles of natural justice by denying petitioner opportunity of oral hearing before passing adverse assessment order raising excess demand. Assessing Authority mandated to afford such opportunity irrespective of petitioner's choice. In assessment orders creating heavy civil liability, granting minimal hearing opportunity essential. Matter remitted to issue fresh notice to petitioner within two weeks for hearing before passing fresh order.
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