Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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