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...
The court held that the impugned order and consequential recovery notice were issued in violation of principles of natural justice as the petitioner was not afforded an opportunity to establish their case before the authorities. The tax demand was recovered from the petitioner without due process. Consequently, the court set aside the impugned order and recovery notice. The matter was remitted back to the respondent authority for reconsideration after allowing the petitioner to file a reply and granting a personal hearing. The writ petition was disposed of accordingly.
The court held that the impugned order and consequential recovery notice were issued in violation of principles of natural justice as the petitioner was not afforded an opportunity to establish their case before the authorities. The tax demand was recovered from the petitioner without due process. Consequently, the court set aside the impugned order and recovery notice. The matter was remitted back to the respondent authority for reconsideration after allowing the petitioner to file a reply and granting a personal hearing. The writ petition was disposed of accordingly.
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