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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Application u/s 154 - grant of interest u/ 244A - On appeal, we find that the CIT(A), being of the view that the impugned order before him was an order passed by the A.O u/s 154 of the Act declining the assessee’s request for rectification, had thus, proceeded with on the basis of the said misconceived factual position and had dismissed the assessee’s appeal, for the reason, that the claim of the assessee did not fall within the realm of a mistake apparent from the record within the meaning of Sec. 154 - Assessee shall in the course of the set-aside proceedings remain at a liberty to substantiate its entitlement for interest u/s 244A on the amount of the self-assessment tax - AT
Application u/s 154 - grant of interest u/ 244A - On appeal, we find that the CIT(A), being of the view that the impugned order before him was an order passed by the A.O u/s 154 of the Act declining the assessee’s request for rectification, had thus, proceeded with on the basis of the said misconceived factual position and had dismissed the assessee’s appeal, for the reason, that the claim of the assessee did not fall within the realm of a mistake apparent from the record within the meaning of Sec. 154 - Assessee shall in the course of the set-aside proceedings remain at a liberty to substantiate its entitlement for interest u/s 244A on the amount of the self-assessment tax - AT
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