Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
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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