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...
Error apparent on record rectified by allowing Revenue's appeal instead of wrongly dismissing it, as logical conclusion of upholding Revenue's contentions. Rectification limited to correcting error on record, not re-hearing matter. Apex Court's guidelines on rectifying apparent errors followed. Request to reconsider monetary limits post-disposal not entertained, as it would reopen decided matters. CESTAT's final order dated 18.03.2024 disposing appeal upheld, no other errors found.
Error apparent on record rectified by allowing Revenue's appeal instead of wrongly dismissing it, as logical conclusion of upholding Revenue's contentions. Rectification limited to correcting error on record, not re-hearing matter. Apex Court's guidelines on rectifying apparent errors followed. Request to reconsider monetary limits post-disposal not entertained, as it would reopen decided matters. CESTAT's final order dated 18.03.2024 disposing appeal upheld, no other errors found.
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