Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
A genuine typographical error in the employer TAN entered in the return can be corrected in exceptional circumstances where the mistake has prevented TDS credit through the system. Although the assessee did not seek rectification within the prescribed time, the Tribunal allowed correction of the TAN particulars and directed the Assessing Officer to grant TDS credit if otherwise admissible under the Act. The relief was limited to permitting correction and ensuring credit only where the substantive entitlement was established.
A genuine typographical error in the employer TAN entered in the return can be corrected in exceptional circumstances where the mistake has prevented TDS credit through the system. Although the assessee did not seek rectification within the prescribed time, the Tribunal allowed correction of the TAN particulars and directed the Assessing Officer to grant TDS credit if otherwise admissible under the Act. The relief was limited to permitting correction and ensuring credit only where the substantive entitlement was established.
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