Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Rectification is available for a mistake apparent from the record, and the record is not confined to the assessment order or intimation alone. A wrong entry in the return showing mutual fund units as acquired on or after 31.01.2018 could be corrected where supporting material in the assessee's record showed acquisition before that date. The authorities were not justified in refusing rectification merely because the correction would alter total income. The matter was restored for verification of the evidence and recomputation of long-term capital gains on the basis that the units were acquired prior to 31.01.2018.
Rectification is available for a mistake apparent from the record, and the record is not confined to the assessment order or intimation alone. A wrong entry in the return showing mutual fund units as acquired on or after 31.01.2018 could be corrected where supporting material in the assessee's record showed acquisition before that date. The authorities were not justified in refusing rectification merely because the correction would alter total income. The matter was restored for verification of the evidence and recomputation of long-term capital gains on the basis that the units were acquired prior to 31.01.2018.
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