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...
An appeal withdrawn after opting for the Vivad Se Vishwas Scheme was restored because the earlier dismissal was only on withdrawal and not on merits. The Tribunal's refusal to revive the appeal was set aside, as the dispute remained undecided and substantial payment had already been made under the settlement scheme. Restoration was necessary so the appeal could be heard in accordance with law, and so the assessee could, if advised, pursue settlement again under the prevailing scheme while the appeal remained pending. The appeal was therefore revived for disposal on merits.
An appeal withdrawn after opting for the Vivad Se Vishwas Scheme was restored because the earlier dismissal was only on withdrawal and not on merits. The Tribunal's refusal to revive the appeal was set aside, as the dispute remained undecided and substantial payment had already been made under the settlement scheme. Restoration was necessary so the appeal could be heard in accordance with law, and so the assessee could, if advised, pursue settlement again under the prevailing scheme while the appeal remained pending. The appeal was therefore revived for disposal on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
