Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Faceless Assessment Unit passed assessment order beyond seven days from show-cause issuance, violating natural justice principles. Submit Response Button deactivation prompted petitioner to file response via Help Desk Grievance Cell, unnoticed by Faceless Assessment Unit. Order u/s 147 read with Section 144B for assessment year 2018-19 set aside due to violation of natural justice and non-compliance with Standard Operating Procedure. Matter remanded to Faceless Assessment Unit to dispose proceedings after considering petitioner's response already on record.
Faceless Assessment Unit passed assessment order beyond seven days from show-cause issuance, violating natural justice principles. Submit Response Button deactivation prompted petitioner to file response via Help Desk Grievance Cell, unnoticed by Faceless Assessment Unit. Order u/s 147 read with Section 144B for assessment year 2018-19 set aside due to violation of natural justice and non-compliance with Standard Operating Procedure. Matter remanded to Faceless Assessment Unit to dispose proceedings after considering petitioner's response already on record.
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