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...
Rectification u/s 154 - No doubt that the income tax authority can rectify any apparent mistake in its order however, when the order of the AO, has been upheld by the ld.CIT(A) and thereafter by the Tribunal, in that eventuality, AO is denuded from rectifying any such mistake, as it would lead to giving unbridled power to AO/ ld.CIT(A) to unsettled the settled position of fact and law and will lead to chaos and anarchy. - There cannot be two contradictory orders of the Tribunal one by upholding the assessment and other quashing the assessment based on the jurisdictional error. - orders of CIT appeals - reversed decided in favour of revenue - AT
Rectification u/s 154 - No doubt that the income tax authority can rectify any apparent mistake in its order however, when the order of the AO, has been upheld by the ld.CIT(A) and thereafter by the Tribunal, in that eventuality, AO is denuded from rectifying any such mistake, as it would lead to giving unbridled power to AO/ ld.CIT(A) to unsettled the settled position of fact and law and will lead to chaos and anarchy. - There cannot be two contradictory orders of the Tribunal one by upholding the assessment and other quashing the assessment based on the jurisdictional error. - orders of CIT appeals - reversed decided in favour of revenue - AT
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