Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
Battery-integrated tablet rear covers classify as lithium-ion accumulators when protective components enable the battery's active energy-storage funct...
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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TaxTMI 
TaxTMI 
of 4891 
