Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Scope of rectification of mistake - The case revolved around the disallowance of EPF and ESI contributions by the Assessing Officer u/s 154 of the Income-tax Act, 1961. The key contention was whether the AO was justified in exercising rectification powers under Section 154 due to conflicting judgments and the absence of a clear error apparent on record. The Appellate Tribunal ruled in favor of the assessee, holding that the AO's action was not justified as the issue was debatable and there was no clear error evident at the time of the original assessment.
Scope of rectification of mistake - The case revolved around the disallowance of EPF and ESI contributions by the Assessing Officer u/s 154 of the Income-tax Act, 1961. The key contention was whether the AO was justified in exercising rectification powers under Section 154 due to conflicting judgments and the absence of a clear error apparent on record. The Appellate Tribunal ruled in favor of the assessee, holding that the AO's action was not justified as the issue was debatable and there was no clear error evident at the time of the original assessment.
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