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...
The HC held that the impugned orders were vitiated due to the absence of signatures on the DRC-07 document, which is a statutory requirement. The court emphasized that when a statute prescribes a specific mode of execution, compliance with that mode is mandatory, and any deviation renders the act invalid. The lack of signatures on DRC-01 and DRC-07 could not be overridden by explanations in the counter affidavit or notes. Consequently, the petition challenging the orders was disposed of in favor of the petitioner, affirming that non-compliance with statutory formalities invalidates the impugned orders.
The HC held that the impugned orders were vitiated due to the absence of signatures on the DRC-07 document, which is a statutory requirement. The court emphasized that when a statute prescribes a specific mode of execution, compliance with that mode is mandatory, and any deviation renders the act invalid. The lack of signatures on DRC-01 and DRC-07 could not be overridden by explanations in the counter affidavit or notes. Consequently, the petition challenging the orders was disposed of in favor of the petitioner, affirming that non-compliance with statutory formalities invalidates the impugned orders.
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