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...
Where identical invoice-related errors were involved, the Court held that benefit under GST Circular No. 183/15/2022-GST could not be denied merely because the circular referred to earlier years, and it could be extended to financial year 2019-20. It further noted that Circular No. 193/05/2023-GST expressly covered the petitioner's relevant period. On that basis, the adjudication order was quashed and the matter was remanded for fresh consideration in accordance with law and the circulars.
Where identical invoice-related errors were involved, the Court held that benefit under GST Circular No. 183/15/2022-GST could not be denied merely because the circular referred to earlier years, and it could be extended to financial year 2019-20. It further noted that Circular No. 193/05/2023-GST expressly covered the petitioner's relevant period. On that basis, the adjudication order was quashed and the matter was remanded for fresh consideration in accordance with law and the circulars.
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