Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
In rectification proceedings, an adverse variation withdrawing relief could not be made ex parte: the Tribunal noted that no notice was issued and that the mandatory opportunity of hearing under section 154(3) was not complied with, so the rectification was void ab initio and set aside. The Tribunal also held that section 154 is confined to correcting a patent mistake apparent from the record and cannot be used to reconsider or reverse a concluded appellate view; where the earlier appellate decision had already favoured the assessee, the later rectification amounted to an impermissible review rather than rectification. The appeal was allowed and the impugned rectification was held unsustainable.
In rectification proceedings, an adverse variation withdrawing relief could not be made ex parte: the Tribunal noted that no notice was issued and that the mandatory opportunity of hearing under section 154(3) was not complied with, so the rectification was void ab initio and set aside. The Tribunal also held that section 154 is confined to correcting a patent mistake apparent from the record and cannot be used to reconsider or reverse a concluded appellate view; where the earlier appellate decision had already favoured the assessee, the later rectification amounted to an impermissible review rather than rectification. The appeal was allowed and the impugned rectification was held unsustainable.
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