Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Rectification of a mistake apparent from the record is confined to patent, self-evident errors and cannot reopen the merits or adopt another possible view. Challenges to the effect of show cause notices, adjudication findings, penal provisions and statutory consequences required reconsideration of the concluded penalty finding for facilitative conduct. As no accidental omission or apparent error was shown, the rectification applications were rejected and the penalty order remained unchanged.
Rectification of a mistake apparent from the record is confined to patent, self-evident errors and cannot reopen the merits or adopt another possible view. Challenges to the effect of show cause notices, adjudication findings, penal provisions and statutory consequences required reconsideration of the concluded penalty finding for facilitative conduct. As no accidental omission or apparent error was shown, the rectification applications were rejected and the penalty order remained unchanged.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4901 
