Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Adverse findings require articulation of the evidential basis and engagement with material facts; where an order imposes penalty on an individual for alleged aiding and abetting but records only conclusory statements that the person received and transferred funds without discussing or identifying supporting evidence, the lack of reasons is fatal and justifies setting aside the penalty and remittal. The operative legal point is that tribunals and adjudicating authorities must record reasoned findings tying conclusions to specific evidence, failing which the affected order cannot be sustained.
Adverse findings require articulation of the evidential basis and engagement with material facts; where an order imposes penalty on an individual for alleged aiding and abetting but records only conclusory statements that the person received and transferred funds without discussing or identifying supporting evidence, the lack of reasons is fatal and justifies setting aside the penalty and remittal. The operative legal point is that tribunals and adjudicating authorities must record reasoned findings tying conclusions to specific evidence, failing which the affected order cannot be sustained.
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