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...
HC found violation of natural justice where SCN was uploaded on 'Additional Notices Tab' without petitioner's knowledge. Following precedent in similar case, HC set aside the impugned order and remanded matter for fresh adjudication. Department mandated to provide personal hearing, consider petitioner's submissions, and pass a reasoned order on merits after giving proper opportunity to respond. Petition disposed of with directions for de novo proceedings ensuring procedural fairness.
HC found violation of natural justice where SCN was uploaded on 'Additional Notices Tab' without petitioner's knowledge. Following precedent in similar case, HC set aside the impugned order and remanded matter for fresh adjudication. Department mandated to provide personal hearing, consider petitioner's submissions, and pass a reasoned order on merits after giving proper opportunity to respond. Petition disposed of with directions for de novo proceedings ensuring procedural fairness.
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