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...
Petitioner, a central public sector undertaking, challenged rejection of its appeal by appellate authority solely on grounds of delay without considering merits. HC quashed appellate order as perverse for mechanically dismissing condonation application without adequately considering petitioner's lack of knowledge about impugned order's issuance. Relying on precedent, HC condoned delay, exercising power u/s 107(4) of the Act, rendering remand to appellate authority unnecessary. Petition disposed of.
Petitioner, a central public sector undertaking, challenged rejection of its appeal by appellate authority solely on grounds of delay without considering merits. HC quashed appellate order as perverse for mechanically dismissing condonation application without adequately considering petitioner's lack of knowledge about impugned order's issuance. Relying on precedent, HC condoned delay, exercising power u/s 107(4) of the Act, rendering remand to appellate authority unnecessary. Petition disposed of.
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