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Deletion of a negative working-capital adjustment in...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range claim.
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Deletion of a negative working-capital adjustment in rectification proceedings required implementation through a consequential appeal-effect order. The Assessing Officer was required to consider whether, after that deletion, the taxpayer's margin fell within the permissible arm's-length range and could reach a contrary conclusion only after giving a reasonable opportunity of hearing. The appeal-effect order was directed to be passed within 15 days, with liberty to seek revival if the consequential order caused grievance.
Deletion of a negative working-capital adjustment in rectification proceedings required implementation through a consequential appeal-effect order. The Assessing Officer was required to consider whether, after that deletion, the taxpayer's margin fell within the permissible arm's-length range and could reach a contrary conclusion only after giving a reasonable opportunity of hearing. The appeal-effect order was directed to be passed within 15 days, with liberty to seek revival if the consequential order caused grievance.
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