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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Rectification of mistake - period of limitation - To give appeal effect of orders passed by the ITAT and issue a refund. - The High Court referred to the interpretation of the term "received" and its implications, emphasizing that the limitation period should commence when the Department becomes aware of the order, not necessarily when the certified copy is physically received. - In light of the principles established in previous cases, including CIT v. Odeon Builders P. Ltd. and Lakhpatrai Agarwal v. CIT, the Court held that the Department's failure to comply with the ITAT's order within the stipulated time was unjustified.
Rectification of mistake - period of limitation - To give appeal effect of orders passed by the ITAT and issue a refund. - The High Court referred to the interpretation of the term "received" and its implications, emphasizing that the limitation period should commence when the Department becomes aware of the order, not necessarily when the certified copy is physically received. - In light of the principles established in previous cases, including CIT v. Odeon Builders P. Ltd. and Lakhpatrai Agarwal v. CIT, the Court held that the Department's failure to comply with the ITAT's order within the stipulated time was unjustified.
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