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...
Rectification of mistake - typographical order - The mistake as alleged is not at all self evident, hence cannot be called as error apparent on record. As for as the plea of cum-tax-benefit is concerned, the plea has not been raised in grounds of appeal. The allegation that the same was not considered by this Tribunal despite been submitted is, therefore, not sustainable.
Rectification of mistake - typographical order - The mistake as alleged is not at all self evident, hence cannot be called as error apparent on record. As for as the plea of cum-tax-benefit is concerned, the plea has not been raised in grounds of appeal. The allegation that the same was not considered by this Tribunal despite been submitted is, therefore, not sustainable.
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