Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Rectification u/s 154 - Capital gain computation - Having admitted to this mistake in his order, there was no other recourse available in law to the Ld.CIT(A) other than allowing assessee’s rectification application. His dismissal of the rectification application on the ground that it would change the CIT(A)’s order is in blatant disregard and against all settled principles of law. If a mistake is admitted to have occurred in an order, the same needs to be rectified. There are no two ways about it. - AT
Rectification u/s 154 - Capital gain computation - Having admitted to this mistake in his order, there was no other recourse available in law to the Ld.CIT(A) other than allowing assessee’s rectification application. His dismissal of the rectification application on the ground that it would change the CIT(A)’s order is in blatant disregard and against all settled principles of law. If a mistake is admitted to have occurred in an order, the same needs to be rectified. There are no two ways about it. - AT
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