Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The note addresses whether a Tribunal appeal survives after an appellate authority corrects an inadvertent reference by rectification. It explains that the appellate order mistakenly referred to a different proceeding, the assessee sought correction, and the appellate authority rectified the order by disposing the appeal against the correct order, thereby granting the relief sought. Because the rectification removed the grievance that formed the basis of the Tribunal appeal, there remained no live controversy and the Tribunal dismissed the appeal as infructuous.
The note addresses whether a Tribunal appeal survives after an appellate authority corrects an inadvertent reference by rectification. It explains that the appellate order mistakenly referred to a different proceeding, the assessee sought correction, and the appellate authority rectified the order by disposing the appeal against the correct order, thereby granting the relief sought. Because the rectification removed the grievance that formed the basis of the Tribunal appeal, there remained no live controversy and the Tribunal dismissed the appeal as infructuous.
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