Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Rectification that withdrew a claimed deduction for an export-oriented unit without stating reasons or issuing any show-cause notice was treated as an impermissible change of opinion rather than correction of a mistake apparent on the record; absence of material justifying rectification and lack of opportunity to be heard rendered the CPC's action unsustainable. The operative effect directed restoration of the deduction as reflected in the assessment intimation, and the assessing officer was ordered to allow the deduction previously granted in the intimation.
Rectification that withdrew a claimed deduction for an export-oriented unit without stating reasons or issuing any show-cause notice was treated as an impermissible change of opinion rather than correction of a mistake apparent on the record; absence of material justifying rectification and lack of opportunity to be heard rendered the CPC's action unsustainable. The operative effect directed restoration of the deduction as reflected in the assessment intimation, and the assessing officer was ordered to allow the deduction previously granted in the intimation.
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