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    <title>2022 (10) TMI 1317 - ITAT DELHI</title>
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    <description>Rectification under section 254(2) was found appropriate where the Tribunal&#039;s own order contained contradictory findings on the comparability of Persistent Systems Ltd., because the inconsistency affected the transfer pricing analysis. The order was recalled to that limited extent for reconsideration of comparability. On Sasken Communication Technologies Ltd., the Tribunal noted that the comparable had already been remanded to the Transfer Pricing Officer, and directed that the assessee&#039;s further functional comparability objections and cited coordinate bench ruling be considered in the fresh exercise. The miscellaneous application was partly accepted for limited rectification and reconsideration of comparability issues.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468892</link>
      <description>Rectification under section 254(2) was found appropriate where the Tribunal&#039;s own order contained contradictory findings on the comparability of Persistent Systems Ltd., because the inconsistency affected the transfer pricing analysis. The order was recalled to that limited extent for reconsideration of comparability. On Sasken Communication Technologies Ltd., the Tribunal noted that the comparable had already been remanded to the Transfer Pricing Officer, and directed that the assessee&#039;s further functional comparability objections and cited coordinate bench ruling be considered in the fresh exercise. The miscellaneous application was partly accepted for limited rectification and reconsideration of comparability issues.</description>
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