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 High Court held that the petitioner should be given an opportunity to place a legible copy of the Bill of Lading and any other required documents before the appellate authority, where the refund claim had been rejected because the document was illegible and the shipping-line contention was treated as unsubstantiated. The matter was directed to be reconsidered afresh on merits after permitting production of the legible Bill of Lading and supporting material, reflecting the application of natural justice in the refund appeal process.
The High Court held that the petitioner should be given an opportunity to place a legible copy of the Bill of Lading and any other required documents before the appellate authority, where the refund claim had been rejected because the document was illegible and the shipping-line contention was treated as unsubstantiated. The matter was directed to be reconsidered afresh on merits after permitting production of the legible Bill of Lading and supporting material, reflecting the application of natural justice in the refund appeal process.
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