Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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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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