Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Rectification of mistake apparent on record is confined to obvious, patent errors and cannot be used to reappreciate evidence or revisit a debatable legal issue, because that would amount to an impermissible review. Applying that principle, the Tribunal noted that the revenue's objection required fresh examination of the assessee's transactions involving agreements for sale, acquisition and relinquishment of rights in immovable property, and the character of the consideration received. As no obvious error on the face of the record was shown, the rectification application was dismissed.
Rectification of mistake apparent on record is confined to obvious, patent errors and cannot be used to reappreciate evidence or revisit a debatable legal issue, because that would amount to an impermissible review. Applying that principle, the Tribunal noted that the revenue's objection required fresh examination of the assessee's transactions involving agreements for sale, acquisition and relinquishment of rights in immovable property, and the character of the consideration received. As no obvious error on the face of the record was shown, the rectification application was dismissed.
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