Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Rectification of mistake apparent on record is confined to obvious, patent errors and cannot be used to reappreciate evidence or revisit a debatable legal issue, because that would amount to an impermissible review. Applying that principle, the Tribunal noted that the revenue's objection required fresh examination of the assessee's transactions involving agreements for sale, acquisition and relinquishment of rights in immovable property, and the character of the consideration received. As no obvious error on the face of the record was shown, the rectification application was dismissed.
Rectification of mistake apparent on record is confined to obvious, patent errors and cannot be used to reappreciate evidence or revisit a debatable legal issue, because that would amount to an impermissible review. Applying that principle, the Tribunal noted that the revenue's objection required fresh examination of the assessee's transactions involving agreements for sale, acquisition and relinquishment of rights in immovable property, and the character of the consideration received. As no obvious error on the face of the record was shown, the rectification application was dismissed.
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