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 dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
The HC dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
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