https://www.taxtmi.com/caselaws?id=64371 Rectification under section 254 was found unavailable because the complaint concerned only the effect of findings already recorded, not any mistake apparent from the record. The Tribunal had already addressed the existence of a business connection and permanent establishment in India, the attribution of profits to Indian operations, and the limited relevance of Circular No. 23 and Morgan Stanley on the facts found. The earlier computation was also upheld: activities wholly outside India, including research and development, were excluded, while profits from marketing and sales functions in India were attributed proportionately. The miscellaneous applications were rejected and the earlier appellate order remained effective. en-us Fri, 30 Jan 2009 00:00:00 +0530 Mon, 30 Oct 2023 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64371 Rectification under section 254 was found unavailable because the complaint concerned only the effect of findings already recorded, not any mistake apparent from the record. The Tribunal had already addressed the existence of a business connection and permanent establishment in India, the attribution of profits to Indian operations, and the limited relevance of Circular No. 23 and Morgan Stanley on the facts found. The earlier computation was also upheld: activities wholly outside India, including research and development, were excluded, while profits from marketing and sales functions in India were attributed proportionately. The miscellaneous applications were rejected and the earlier appellate order remained effective. Case-Laws Income Tax Fri, 30 Jan 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64371