Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Quantification of CIRP cost - monthly fees payable to the Applicant under the Service Agreement - This Tribunal has clearly laid down that findings on questions of fact, how-so-ever erroneous cannot be allowed to be questioned. However, mistake which have due to oversight, inadvertence or human error can be corrected. Further it was held that it would be open to correct the conclusion if the same is not compatible with the finding recorded on the issues raised. - AT
Quantification of CIRP cost - monthly fees payable to the Applicant under the Service Agreement - This Tribunal has clearly laid down that findings on questions of fact, how-so-ever erroneous cannot be allowed to be questioned. However, mistake which have due to oversight, inadvertence or human error can be corrected. Further it was held that it would be open to correct the conclusion if the same is not compatible with the finding recorded on the issues raised. - AT
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