Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
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 
