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 unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
An unauthenticated transfer pricing order issued without signature was held invalid and non est in law because no signed order of the Transfer Pricing Officer was placed on record. The Tribunal rejected reliance on the faceless assessment procedure as irrelevant on the facts noted. As the order under section 92CA(3) lacked authentication, it could not be recognised in law, and the impugned assessments for both assessment years were quashed. The assessee's appeals were therefore allowed on this legal ground.
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