Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Rectification for a mistake apparent from the record is limited to patent, manifest and self-evident errors identifiable without prolonged reasoning. Detailed challenges to remand directions on an AMP transfer-pricing adjustment or an associated-enterprise share purchase seek a review on merits and fall outside section 254(2); those rectification requests fail. Omission to decide an unrebutted claim for TDS credit constitutes a rectifiable omission. Supporting evidence requires verification before TDS credit is granted in accordance with law, while the remaining rectification claims do not survive.
Rectification for a mistake apparent from the record is limited to patent, manifest and self-evident errors identifiable without prolonged reasoning. Detailed challenges to remand directions on an AMP transfer-pricing adjustment or an associated-enterprise share purchase seek a review on merits and fall outside section 254(2); those rectification requests fail. Omission to decide an unrebutted claim for TDS credit constitutes a rectifiable omission. Supporting evidence requires verification before TDS credit is granted in accordance with law, while the remaining rectification claims do not survive.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
