https://www.taxtmi.com/caselaws?id=280168 Rectification under section 254(2) was held unavailable where the assessee sought to reopen a transfer pricing finding already decided on merits. The Tribunal applied sections 92, 92B and 92C read with rule 10B and reiterated that the Indian transfer pricing framework requires comparison of the assessee's international transaction with uncontrolled comparables, not substitution of the foreign associated enterprise's profit as the tested party benchmark. It also noted that the cited decisions did not displace that approach. The requested relief was treated as a review of the earlier order, which lies beyond the limited scope of section 254(2), and the rectification application was rejected. en-us Fri, 17 Jan 2014 00:00:00 +0530 Tue, 23 Apr 2019 21:26:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280168 Rectification under section 254(2) was held unavailable where the assessee sought to reopen a transfer pricing finding already decided on merits. The Tribunal applied sections 92, 92B and 92C read with rule 10B and reiterated that the Indian transfer pricing framework requires comparison of the assessee's international transaction with uncontrolled comparables, not substitution of the foreign associated enterprise's profit as the tested party benchmark. It also noted that the cited decisions did not displace that approach. The requested relief was treated as a review of the earlier order, which lies beyond the limited scope of section 254(2), and the rectification application was rejected. Case-Laws Income Tax Fri, 17 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280168