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 Appellate Tribunal allowed the appeal and remanded the matter to the adjudicating authority for passing a fresh order. The Tribunal found that the refund claim was erroneously rejected by the lower authorities on the ground of limitation u/s 11B, as there was an inconsistency in treating part of the amount paid as a pre-deposit and the remaining amount differently, despite being of the same nature. The Tribunal set aside the impugned order, holding that the issue required reconsideration by the adjudicating authority.
The Appellate Tribunal allowed the appeal and remanded the matter to the adjudicating authority for passing a fresh order. The Tribunal found that the refund claim was erroneously rejected by the lower authorities on the ground of limitation u/s 11B, as there was an inconsistency in treating part of the amount paid as a pre-deposit and the remaining amount differently, despite being of the same nature. The Tribunal set aside the impugned order, holding that the issue required reconsideration by the adjudicating authority.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
