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...
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.
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