https://www.taxtmi.com/caselaws?id=312270 ITAT Kolkata partially allowed the assessee's rectification application under section 254(2). The Tribunal recalled its order dated 26.03.2021 for limited adjudication of the application for admission of additional grounds and Ground No.6-7 regarding interest levy under sections 234B and 234D, finding these omissions constituted errors apparent on record. However, the Tribunal rejected the assessee's claim regarding non-consideration of certain facts in transfer pricing benchmarking, holding that the challenged observation was not the sole basis for the conclusion and that failure to consider specific arguments constitutes error of judgment, not error apparent on record requiring rectification. en-us Fri, 27 May 2022 00:00:00 +0530 Fri, 09 Feb 2024 18:27:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312270 ITAT Kolkata partially allowed the assessee's rectification application under section 254(2). The Tribunal recalled its order dated 26.03.2021 for limited adjudication of the application for admission of additional grounds and Ground No.6-7 regarding interest levy under sections 234B and 234D, finding these omissions constituted errors apparent on record. However, the Tribunal rejected the assessee's claim regarding non-consideration of certain facts in transfer pricing benchmarking, holding that the challenged observation was not the sole basis for the conclusion and that failure to consider specific arguments constitutes error of judgment, not error apparent on record requiring rectification. Case-Laws Income Tax Fri, 27 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312270