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 under section 154 is confined to manifest, patent and self-evident mistakes apparent from the record; it cannot resolve issues requiring factual examination, legal interpretation or a choice between possible views. Although non-consideration of a binding judgment may constitute such a mistake, disputed computation of taxable income after denial of exemption to an educational society-including treatment of capital receipts and capital expenditure-requires examination of the nature of receipts, expenditure and the applicable computation method. As those questions were debatable and formed part of a pending quantum appeal, rectification could not be used as a review mechanism or substitute for appellate adjudication. The rectification application was therefore rejected, subject to pursuit of grounds in the quantum appeal.
Rectification under section 154 is confined to manifest, patent and self-evident mistakes apparent from the record; it cannot resolve issues requiring factual examination, legal interpretation or a choice between possible views. Although non-consideration of a binding judgment may constitute such a mistake, disputed computation of taxable income after denial of exemption to an educational society-including treatment of capital receipts and capital expenditure-requires examination of the nature of receipts, expenditure and the applicable computation method. As those questions were debatable and formed part of a pending quantum appeal, rectification could not be used as a review mechanism or substitute for appellate adjudication. The rectification application was therefore rejected, subject to pursuit of grounds in the quantum appeal.
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