Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
The ITAT rectified its earlier appellate order under the mistake apparent from record doctrine by correcting the recorded basis for relief on corporate guarantee fee and MEIS export incentives. For the corporate guarantee issue, the correction clarified that non-interference rested on earlier-year acceptance by the TPO/AO at arm's length and absence of any change in facts, rather than on coordinate Bench rulings. For MEIS incentives, the order was amended to reflect reliance on Chennai, Delhi and Mumbai ITAT decisions and the Commissioner (Appeals)'s earlier-year orders. The miscellaneous application was allowed, and the substantive outcome remained unchanged.
The ITAT rectified its earlier appellate order under the mistake apparent from record doctrine by correcting the recorded basis for relief on corporate guarantee fee and MEIS export incentives. For the corporate guarantee issue, the correction clarified that non-interference rested on earlier-year acceptance by the TPO/AO at arm's length and absence of any change in facts, rather than on coordinate Bench rulings. For MEIS incentives, the order was amended to reflect reliance on Chennai, Delhi and Mumbai ITAT decisions and the Commissioner (Appeals)'s earlier-year orders. The miscellaneous application was allowed, and the substantive outcome remained unchanged.
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