https://www.taxtmi.com/caselaws?id=757777 The Karnataka HC upheld the DRP's rectification under section 154 of the Income Tax Act regarding AMP expenses in a transfer pricing case. The assessee had provided specific details about trade discounts, warranty expenses, and packing expenses to the DRP during objections to the draft order, which were not considered in the original assessment. The HC held that when an order is passed without considering materials on record, the authority can rectify such mistake apparent from the record under section 154. The DRP correctly excluded these expenses from AMP expenses for transfer pricing comparison purposes. The Appellate Tribunal's finding that non-consideration of available material constitutes a mistake apparent from record was upheld, and the DRP's jurisdiction under section 154 was justified. en-us Mon, 12 Aug 2024 00:00:00 +0530 Fri, 03 Jul 2026 15:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757777 The Karnataka HC upheld the DRP's rectification under section 154 of the Income Tax Act regarding AMP expenses in a transfer pricing case. The assessee had provided specific details about trade discounts, warranty expenses, and packing expenses to the DRP during objections to the draft order, which were not considered in the original assessment. The HC held that when an order is passed without considering materials on record, the authority can rectify such mistake apparent from the record under section 154. The DRP correctly excluded these expenses from AMP expenses for transfer pricing comparison purposes. The Appellate Tribunal's finding that non-consideration of available material constitutes a mistake apparent from record was upheld, and the DRP's jurisdiction under section 154 was justified. Case-Laws Income Tax Mon, 12 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757777