Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Rectification u/s 154 application rejected as being time barred - The Appellate Tribunal agreed with the assessee's contention that the rectification application was not time-barred. It held that the clock for the four-year limitation period starts only when the assessee is in receipt of the order to be rectified. Since there was no evidence that the intimation under Section 143(1) was served on the assessee, the limitation period did not begin, and the application was well within the stipulated time.
Rectification u/s 154 application rejected as being time barred - The Appellate Tribunal agreed with the assessee's contention that the rectification application was not time-barred. It held that the clock for the four-year limitation period starts only when the assessee is in receipt of the order to be rectified. Since there was no evidence that the intimation under Section 143(1) was served on the assessee, the limitation period did not begin, and the application was well within the stipulated time.
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