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...
Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.
Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.
Note: It is a system-generated summary and is for quick reference only.