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 held that the impugned notice and order were quashed due to lack of jurisdictional propriety. The respondent-Authority failed to provide adequate intimation regarding ITC reversal, and the petitioner demonstrated genuine unawareness of procedural requirements. The Court remanded the matter back to the Adjudicating Authority to conduct a de novo examination of ITC reversal for 2017-18, directing a fresh order within twelve weeks. While the Appellate Authority had dismissed the appeal on delay grounds, the HC recognized procedural constraints and procedural fairness, effectively setting aside the original order and providing an opportunity for proper administrative review.
HC held that the impugned notice and order were quashed due to lack of jurisdictional propriety. The respondent-Authority failed to provide adequate intimation regarding ITC reversal, and the petitioner demonstrated genuine unawareness of procedural requirements. The Court remanded the matter back to the Adjudicating Authority to conduct a de novo examination of ITC reversal for 2017-18, directing a fresh order within twelve weeks. While the Appellate Authority had dismissed the appeal on delay grounds, the HC recognized procedural constraints and procedural fairness, effectively setting aside the original order and providing an opportunity for proper administrative review.
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