https://www.taxtmi.com/caselaws?id=401933 Rectification under section 254(2) is limited to an obvious, manifest and patent mistake on the face of the record and cannot be used to reargue or review a concluded Tribunal order. The assessee's miscellaneous applications sought, in substance, to reopen findings on transfer pricing documentation and the penalty under section 271AA, but the Tribunal found no apparent error in its earlier decision. It also distinguished Form 3CEB from the documentation requirements under sections 92D and 92E, and held that the applications did not disclose any mistake warranting recall. en-us Fri, 18 Dec 2020 00:00:00 +0530 Wed, 28 Jul 2021 18:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401933 Rectification under section 254(2) is limited to an obvious, manifest and patent mistake on the face of the record and cannot be used to reargue or review a concluded Tribunal order. The assessee's miscellaneous applications sought, in substance, to reopen findings on transfer pricing documentation and the penalty under section 271AA, but the Tribunal found no apparent error in its earlier decision. It also distinguished Form 3CEB from the documentation requirements under sections 92D and 92E, and held that the applications did not disclose any mistake warranting recall. Case-Laws Income Tax Fri, 18 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401933