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...
Imposition of a general penalty where concurrent assessment orders exist was held arbitrary under the doctrine against double punishment; consequence: the general penalty of Rs.50,000 was set aside. The liability for late fee was sustained on merits and the petitioner was directed to pay Rs.1,67,200 within 30 days; consequence: on compliance the impugned assessment order and recovery proceedings will be quashed and dropped immediately. Failure to comply permits recovery as if the petition were dismissed. Writ Petition disposed accordingly.
Imposition of a general penalty where concurrent assessment orders exist was held arbitrary under the doctrine against double punishment; consequence: the general penalty of Rs.50,000 was set aside. The liability for late fee was sustained on merits and the petitioner was directed to pay Rs.1,67,200 within 30 days; consequence: on compliance the impugned assessment order and recovery proceedings will be quashed and dropped immediately. Failure to comply permits recovery as if the petition were dismissed. Writ Petition disposed accordingly.
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