Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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Rectification under section 254(2) is confined to obvious, patent and self-evident mistakes on the record, and cannot be used to reopen the merits or seek review of an earlier appellate order. The Tribunal held that the Revenue's complaint of non-consideration of authorities and instructions was, in substance, an attempt to reargue the matter and revisit the decision, not a true rectifiable error. It also noted that a similar contention had already been rejected in an earlier miscellaneous application. The miscellaneous application was therefore found to be without merit and dismissed as an impermissible review request.
Rectification under section 254(2) is confined to obvious, patent and self-evident mistakes on the record, and cannot be used to reopen the merits or seek review of an earlier appellate order. The Tribunal held that the Revenue's complaint of non-consideration of authorities and instructions was, in substance, an attempt to reargue the matter and revisit the decision, not a true rectifiable error. It also noted that a similar contention had already been rejected in an earlier miscellaneous application. The miscellaneous application was therefore found to be without merit and dismissed as an impermissible review request.
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