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...
Impugned show cause notice reproduced provisions of Section 29(2)(e) without specifying alleged fraud, misstatement or suppression of facts by petitioner. Cancellation order passed in violation of principles of natural justice. Instead of setting aside cancellation order, order rejecting revocation application set aside to provide opportunity to respond to allegations. Petition disposed.
Impugned show cause notice reproduced provisions of Section 29(2)(e) without specifying alleged fraud, misstatement or suppression of facts by petitioner. Cancellation order passed in violation of principles of natural justice. Instead of setting aside cancellation order, order rejecting revocation application set aside to provide opportunity to respond to allegations. Petition disposed.
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