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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Rectification u/s 254 - Addition u/s 68 - non-consideration of certain facts in Order of the Tribunal - ignoring the material already on record on the part of the learned Tribunal was a mistake apparent on the face of record u/s 254 and Tribunal has, in our opinion, rightly recalled its order and rectified the mistake and it has rightly set aside the additions under Section 68 of the Act and they are only findings of facts based on relevant material. - HC
Rectification u/s 254 - Addition u/s 68 - non-consideration of certain facts in Order of the Tribunal - ignoring the material already on record on the part of the learned Tribunal was a mistake apparent on the face of record u/s 254 and Tribunal has, in our opinion, rightly recalled its order and rectified the mistake and it has rightly set aside the additions under Section 68 of the Act and they are only findings of facts based on relevant material. - HC
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