Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Rectification of mistake u/s 254 - period of limitation - keeping in view factual matrix of the instant case, the MA ought to have been filed by assessee latest by 30.11.2016 viz. six months from the date new amended provision came into effect, as on the date of amendment on 01.06.2016, in the instant case, the unexpired limitation period under the old law was more than six month. The assessee has filed this MA on 20.01.2017 which is clearly time barred keeping in view amended provisions of Section 254(2), and hence this MA is not maintainable. - AT
Rectification of mistake u/s 254 - period of limitation - keeping in view factual matrix of the instant case, the MA ought to have been filed by assessee latest by 30.11.2016 viz. six months from the date new amended provision came into effect, as on the date of amendment on 01.06.2016, in the instant case, the unexpired limitation period under the old law was more than six month. The assessee has filed this MA on 20.01.2017 which is clearly time barred keeping in view amended provisions of Section 254(2), and hence this MA is not maintainable. - AT
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