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...
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.
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