Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Direct appeals to the Tribunal against an Assessing Officer's rectification order under section 154 are not maintainable where the statutory appeal to the Commissioner (Appeals) has not first been filed. The prescribed appellate sequence requires the aggrieved taxpayer to pursue the first appellate remedy before approaching the Tribunal. An erroneous reference in Form No. 36 to a Commissioner (Appeals) order does not convert the proceeding into a valid appeal against that order.
Direct appeals to the Tribunal against an Assessing Officer's rectification order under section 154 are not maintainable where the statutory appeal to the Commissioner (Appeals) has not first been filed. The prescribed appellate sequence requires the aggrieved taxpayer to pursue the first appellate remedy before approaching the Tribunal. An erroneous reference in Form No. 36 to a Commissioner (Appeals) order does not convert the proceeding into a valid appeal against that order.
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