https://www.taxtmi.com/caselaws?id=246845 Rectification jurisdiction under section 254(2) was addressed: the Tribunal held that an apparent, manifest error is required and it cannot be used to reopen merits; the rectification plea failed and relief was denied. Transfer pricing issues on selection and comparability of benchmarks were remanded to AO/TPO to consider segmental results and relatedparty transactions in the ITES segment, with several contested comparables (brand value, turnover, alleged fraud) rejected on the facts. The Tribunal affirmed that tolerance ranges for comparables and fresh searches by TPO were matters of merit, not rectification. en-us Wed, 13 Nov 2013 00:00:00 +0530 Thu, 05 Feb 2026 10:26:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246845 Rectification jurisdiction under section 254(2) was addressed: the Tribunal held that an apparent, manifest error is required and it cannot be used to reopen merits; the rectification plea failed and relief was denied. Transfer pricing issues on selection and comparability of benchmarks were remanded to AO/TPO to consider segmental results and relatedparty transactions in the ITES segment, with several contested comparables (brand value, turnover, alleged fraud) rejected on the facts. The Tribunal affirmed that tolerance ranges for comparables and fresh searches by TPO were matters of merit, not rectification. Case-Laws Income Tax Wed, 13 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246845