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...
Validity of reopening of assessment was examined and the impugned reassessment order was quashed because the stated reasons for reopening did not align with the reasons in the order; the matter is remitted for fresh adjudication. The remand requires the assessing authority to afford the taxpayer another opportunity to file a detailed reply with supporting documents and to decide the matter on merits in accordance with law. The impugned order is to be treated as an addendum to the pre-assessment show cause notice and the petitioner must upload its reply when the portal permits; writ petition disposed.
Validity of reopening of assessment was examined and the impugned reassessment order was quashed because the stated reasons for reopening did not align with the reasons in the order; the matter is remitted for fresh adjudication. The remand requires the assessing authority to afford the taxpayer another opportunity to file a detailed reply with supporting documents and to decide the matter on merits in accordance with law. The impugned order is to be treated as an addendum to the pre-assessment show cause notice and the petitioner must upload its reply when the portal permits; writ petition disposed.
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