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...
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
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