https://www.taxtmi.com/caselaws?id=292687 Section 254(2) permits rectification only of manifest clerical or factual mistakes, not reconsideration of substantive reasoning on issues such as the relationship between the parties, the nature of advertisement airtime, or transfer pricing and treaty analysis. The Tribunal therefore corrected only clear record errors, including the description of channel ownership, dates in the cause title, and an erroneous sentence, while leaving the substantive reasoning unchanged. Where a ground in one appeal had not been adjudicated, the omission was treated as an apparent error requiring recall only to the limited extent necessary to decide that ground. The substantive findings otherwise remained undisturbed. en-us Wed, 23 Nov 2016 00:00:00 +0530 Mon, 04 Jan 2021 19:45:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=292687 Section 254(2) permits rectification only of manifest clerical or factual mistakes, not reconsideration of substantive reasoning on issues such as the relationship between the parties, the nature of advertisement airtime, or transfer pricing and treaty analysis. The Tribunal therefore corrected only clear record errors, including the description of channel ownership, dates in the cause title, and an erroneous sentence, while leaving the substantive reasoning unchanged. Where a ground in one appeal had not been adjudicated, the omission was treated as an apparent error requiring recall only to the limited extent necessary to decide that ground. The substantive findings otherwise remained undisturbed. Case-Laws Income Tax Wed, 23 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=292687