Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Rectification jurisdiction is confined to correcting mistakes apparent from the record and is comparable to the limited review standard under the Civil Procedure Code. It does not permit the Tribunal to revisit a detailed merits order, reconsider factual aspects of reassessment, or re-appreciate the controversy merely because the earlier decision is alleged to be erroneous. Where a merits order is challenged as erroneous, the appropriate course is the statutory appellate remedy rather than recall through rectification. The text states that a recall exceeding this limited jurisdiction was set aside and the original appellate order restored.
Rectification jurisdiction is confined to correcting mistakes apparent from the record and is comparable to the limited review standard under the Civil Procedure Code. It does not permit the Tribunal to revisit a detailed merits order, reconsider factual aspects of reassessment, or re-appreciate the controversy merely because the earlier decision is alleged to be erroneous. Where a merits order is challenged as erroneous, the appropriate course is the statutory appellate remedy rather than recall through rectification. The text states that a recall exceeding this limited jurisdiction was set aside and the original appellate order restored.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
