https://www.taxtmi.com/caselaws?id=216054 Rectification under section 254(2) extends to patent mistakes apparent from the record, including a typographical omission of the word "not", and may be exercised suo motu after hearing the affected party. The Tribunal also expunged an unnecessary earlier reference to the force of attraction rule under Article 7(1) because the appeal had already been decided on the basis that no permanent establishment existed in India. However, the request to confine the remand on Article 13 to the value of replacement components was rejected, as the taxability issue had not been examined below and no glaring error justified narrowing the remand. The rectification application succeeded only for correction of obvious errors. en-us Mon, 28 Feb 2011 00:00:00 +0530 Wed, 29 Aug 2012 09:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216054 Rectification under section 254(2) extends to patent mistakes apparent from the record, including a typographical omission of the word "not", and may be exercised suo motu after hearing the affected party. The Tribunal also expunged an unnecessary earlier reference to the force of attraction rule under Article 7(1) because the appeal had already been decided on the basis that no permanent establishment existed in India. However, the request to confine the remand on Article 13 to the value of replacement components was rejected, as the taxability issue had not been examined below and no glaring error justified narrowing the remand. The rectification application succeeded only for correction of obvious errors. Case-Laws Income Tax Mon, 28 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216054