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 application u/s 254 - Tribunal not followed the decision on the identical facts by the Coordinate Bench which is confirmed by this Court - The Court emphasized the principle of judicial consistency and the hierarchical nature of judicial decisions, reiterating that lower tribunals are bound by the decisions of their supervisory jurisdictions. As such, ignoring these precedents constituted a mistake apparent from the record, necessitating a review and correction of the Tribunal's decision. The Court remanded the case back to the Tribunal, directing it to amend its decision in alignment with the precedents highlighted by the petitioner.
Rectification application u/s 254 - Tribunal not followed the decision on the identical facts by the Coordinate Bench which is confirmed by this Court - The Court emphasized the principle of judicial consistency and the hierarchical nature of judicial decisions, reiterating that lower tribunals are bound by the decisions of their supervisory jurisdictions. As such, ignoring these precedents constituted a mistake apparent from the record, necessitating a review and correction of the Tribunal's decision. The Court remanded the case back to the Tribunal, directing it to amend its decision in alignment with the precedents highlighted by the petitioner.
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