https://www.taxtmi.com/caselaws?id=797895 Rule 13 confines rectification of apparent mistakes to suo motu action or applications by the eligible assessee or Assessing Officer. Rectified DRP directions initiated on an application by the Commissioner of Income-tax (Departmental Representative) were therefore invalid, and replacing the original benchmarking method with intensity-adjusted TNMM was an impermissible review rather than rectification. The consequential assessment order and protective addition could not stand, including because they conflicted with binding DRP directions. Transfer-pricing adjustments for advertisement, marketing and promotion expenditure based on the Bright Line Test and intensity-adjusted TNMM were also unsustainable and were deleted. en-us Fri, 21 Aug 2026 00:00:00 +0530 Sat, 29 Aug 2026 14:35:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797895 Rule 13 confines rectification of apparent mistakes to suo motu action or applications by the eligible assessee or Assessing Officer. Rectified DRP directions initiated on an application by the Commissioner of Income-tax (Departmental Representative) were therefore invalid, and replacing the original benchmarking method with intensity-adjusted TNMM was an impermissible review rather than rectification. The consequential assessment order and protective addition could not stand, including because they conflicted with binding DRP directions. Transfer-pricing adjustments for advertisement, marketing and promotion expenditure based on the Bright Line Test and intensity-adjusted TNMM were also unsustainable and were deleted. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797895