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...
ITAT held that an appeal against a rectification order under section 154 cannot be used to challenge the original addition where the rectification merely corrected a computation mistake apparent from the record and did not disturb the substantive assessment. As the assessee's grievance was in substance against the addition itself, the proper remedy was to appeal the original assessment order, not the rectification order. The appeal against the rectification order was therefore rightly dismissed. The Tribunal clarified that this dismissal would not prevent the assessee from separately challenging the original assessment order in accordance with law, subject to limitation, with all contentions left open.
ITAT held that an appeal against a rectification order under section 154 cannot be used to challenge the original addition where the rectification merely corrected a computation mistake apparent from the record and did not disturb the substantive assessment. As the assessee's grievance was in substance against the addition itself, the proper remedy was to appeal the original assessment order, not the rectification order. The appeal against the rectification order was therefore rightly dismissed. The Tribunal clarified that this dismissal would not prevent the assessee from separately challenging the original assessment order in accordance with law, subject to limitation, with all contentions left open.
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