Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Rectification for a mistake apparent from the record is limited to patent, manifest and self-evident errors identifiable without prolonged reasoning. Detailed challenges to remand directions on an AMP transfer-pricing adjustment or an associated-enterprise share purchase seek a review on merits and fall outside section 254(2); those rectification requests fail. Omission to decide an unrebutted claim for TDS credit constitutes a rectifiable omission. Supporting evidence requires verification before TDS credit is granted in accordance with law, while the remaining rectification claims do not survive.
Rectification for a mistake apparent from the record is limited to patent, manifest and self-evident errors identifiable without prolonged reasoning. Detailed challenges to remand directions on an AMP transfer-pricing adjustment or an associated-enterprise share purchase seek a review on merits and fall outside section 254(2); those rectification requests fail. Omission to decide an unrebutted claim for TDS credit constitutes a rectifiable omission. Supporting evidence requires verification before TDS credit is granted in accordance with law, while the remaining rectification claims do not survive.
Note: It is a system-generated summary and is for quick reference only.
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