Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
