https://www.taxtmi.com/caselaws?id=764828 ITAT Mumbai rejected the rectification application filed by the assessee regarding securities losses recovery and transfer pricing adjustments. The tribunal clarified that securities losses recovery for AY 2002-03 would not be taxed if revenue succeeds in appeal for AY 1993-94 before HC/SC and deduction is disallowed. Regarding transfer pricing, ITAT upheld its earlier direction for verification of CPA certificate and allocation key, ruling that authorities below had rejected benefit test at threshold without examining supporting documents. The tribunal distinguished between mistake apparent on record and error of judgment, holding that remand directions constituted the latter, which falls outside rectification powers under Section 254(2) and is subject to appellate review under Section 260A. en-us Mon, 16 Dec 2024 00:00:00 +0530 Sat, 18 Jan 2025 08:49:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764828 ITAT Mumbai rejected the rectification application filed by the assessee regarding securities losses recovery and transfer pricing adjustments. The tribunal clarified that securities losses recovery for AY 2002-03 would not be taxed if revenue succeeds in appeal for AY 1993-94 before HC/SC and deduction is disallowed. Regarding transfer pricing, ITAT upheld its earlier direction for verification of CPA certificate and allocation key, ruling that authorities below had rejected benefit test at threshold without examining supporting documents. The tribunal distinguished between mistake apparent on record and error of judgment, holding that remand directions constituted the latter, which falls outside rectification powers under Section 254(2) and is subject to appellate review under Section 260A. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764828