https://www.taxtmi.com/caselaws?id=405487 Rectification under section 254(2) was unavailable because the miscellaneous application did not show any mistake apparent from the record. The application effectively sought to re-open the merits of the Tribunal's earlier order by disputing its treatment of the transfer pricing guideline and by relying on an additional decision not specifically discussed. The Tribunal noted that the earlier order had already considered the relevant CBDT guideline, the transfer pricing adjustment, and the consequence of non-reference to the TPO. It also stated that not every cited judgment must be separately addressed unless applicable on the facts, and that a review-style challenge cannot be pursued through rectification. en-us Tue, 09 Mar 2021 00:00:00 +0530 Tue, 29 Oct 2024 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405487 Rectification under section 254(2) was unavailable because the miscellaneous application did not show any mistake apparent from the record. The application effectively sought to re-open the merits of the Tribunal's earlier order by disputing its treatment of the transfer pricing guideline and by relying on an additional decision not specifically discussed. The Tribunal noted that the earlier order had already considered the relevant CBDT guideline, the transfer pricing adjustment, and the consequence of non-reference to the TPO. It also stated that not every cited judgment must be separately addressed unless applicable on the facts, and that a review-style challenge cannot be pursued through rectification. Case-Laws Income Tax Tue, 09 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405487