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...
Condonation of delay in receipt of export remittance under the CGST framework requires a reasoned order and opportunity for hearing; a mere communication or intimation cannot substitute for an order. The impugned communication purportedly rejecting the petitioner's representation was not a reasoned order and no hearing was afforded. The matter is remitted to the competent commissioner to reconsider the condonation request afresh, afford the petitioner an opportunity to be heard, and pass a reasoned decision addressing the grounds raised by the petitioner.
Condonation of delay in receipt of export remittance under the CGST framework requires a reasoned order and opportunity for hearing; a mere communication or intimation cannot substitute for an order. The impugned communication purportedly rejecting the petitioner's representation was not a reasoned order and no hearing was afforded. The matter is remitted to the competent commissioner to reconsider the condonation request afresh, afford the petitioner an opportunity to be heard, and pass a reasoned decision addressing the grounds raised by the petitioner.
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