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 petitioner challenged the issuance of multiple audit memos determining tax liability beyond the stipulated period u/s 65(4) of the CGST/DGST Act. While the multiple audit memos indicating findings and demanding tax payment were irregular u/s 65(6), the impugned show cause notice (SCN) premised on the audit report findings is within the statutory framework. Any irregularities in issuing audit memos do not impinge the validity of the SCN. Therefore, the petition to quash the SCN at the threshold stage cannot be accepted, and the petition is disposed of.
The petitioner challenged the issuance of multiple audit memos determining tax liability beyond the stipulated period u/s 65(4) of the CGST/DGST Act. While the multiple audit memos indicating findings and demanding tax payment were irregular u/s 65(6), the impugned show cause notice (SCN) premised on the audit report findings is within the statutory framework. Any irregularities in issuing audit memos do not impinge the validity of the SCN. Therefore, the petition to quash the SCN at the threshold stage cannot be accepted, and the petition is disposed of.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
