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 of mistake u/s 154 - Though there is a remedy to revise the return but if the assessee could not revised its return of income within the period prescribed, it does not mean that there is no remedy for such a mistake leading to incorrect assessment. Even otherwise, if assessee has offered an income to tax by mistake or due to technical mal functioning of computer system, the appellate authority has the jurisdiction to rectify such mistake and particularly to avoid the assessment of the income which is not the real income of the assessee. - AT
Rectification of mistake u/s 154 - Though there is a remedy to revise the return but if the assessee could not revised its return of income within the period prescribed, it does not mean that there is no remedy for such a mistake leading to incorrect assessment. Even otherwise, if assessee has offered an income to tax by mistake or due to technical mal functioning of computer system, the appellate authority has the jurisdiction to rectify such mistake and particularly to avoid the assessment of the income which is not the real income of the assessee. - AT
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