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...
Rectification jurisdiction permits correction only of a patent, manifest or self-evident error, not reassessment of evidence or review of an earlier view. Claims that additions for alleged on-money receipts failed to consider seized material, related orders, a co-ordinate Bench decision and precedents on income extrapolation did not establish a mistake apparent from the record where those materials had been considered. The rectification applications therefore amounted to an impermissible review and were dismissed.
Rectification jurisdiction permits correction only of a patent, manifest or self-evident error, not reassessment of evidence or review of an earlier view. Claims that additions for alleged on-money receipts failed to consider seized material, related orders, a co-ordinate Bench decision and precedents on income extrapolation did not establish a mistake apparent from the record where those materials had been considered. The rectification applications therefore amounted to an impermissible review and were dismissed.
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