Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
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