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 dismissed the assessee's miscellaneous application seeking rectification under section 254(2). The tribunal held that the application was essentially attempting to review the original order, which is impermissible under law. Established judicial precedent confirms that review disguised as rectification is not allowed. An oversight of fact or failure to consider an argument does not constitute an apparent mistake rectifiable under the provision. The tribunal's original findings on section 69A and 115BBE remained unchanged, and the application was rejected on procedural grounds, maintaining the integrity of the original appellate order.
ITAT dismissed the assessee's miscellaneous application seeking rectification under section 254(2). The tribunal held that the application was essentially attempting to review the original order, which is impermissible under law. Established judicial precedent confirms that review disguised as rectification is not allowed. An oversight of fact or failure to consider an argument does not constitute an apparent mistake rectifiable under the provision. The tribunal's original findings on section 69A and 115BBE remained unchanged, and the application was rejected on procedural grounds, maintaining the integrity of the original appellate order.
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