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...
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The HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
The HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
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