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...
SC dismissed the SLP due to a 295-day delay in filing, which remained unexplained by the petitioners. The underlying tax matter concerned an assessment order under Section 144C, where the FAO's order was deemed time-barred two years after DRP directions. The HC previously ruled that the original return of income must be accepted, entitling the petitioner to a refund with applicable interest. The procedural requirement mandated completion within 30 days of the order's upload. The SLP was consequently rejected on procedural grounds of delay, without examining the substantive tax dispute.
SC dismissed the SLP due to a 295-day delay in filing, which remained unexplained by the petitioners. The underlying tax matter concerned an assessment order under Section 144C, where the FAO's order was deemed time-barred two years after DRP directions. The HC previously ruled that the original return of income must be accepted, entitling the petitioner to a refund with applicable interest. The procedural requirement mandated completion within 30 days of the order's upload. The SLP was consequently rejected on procedural grounds of delay, without examining the substantive tax dispute.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
