https://www.taxtmi.com/caselaws?id=471569 Rectification under section 254(2) is confined to patent mistakes apparent from the record and cannot be used to review a reasoned decision on facts or law; reconsideration of an amended provision and denial of weighted deduction must be pursued through appellate review. Fresh transfer-pricing benchmarking under TNMM must be undertaken independently for each assessment year using that year's financial data, even where TNMM is accepted as the most appropriate method. Accordingly, the remand for fresh arm's length price determination remains operative, but the clarification concerning comparative associated-enterprise and non-associated-enterprise segment margins was deleted to remove ambiguity. en-us Mon, 19 Feb 2024 00:00:00 +0530 Wed, 09 Sep 2026 16:11:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471569 Rectification under section 254(2) is confined to patent mistakes apparent from the record and cannot be used to review a reasoned decision on facts or law; reconsideration of an amended provision and denial of weighted deduction must be pursued through appellate review. Fresh transfer-pricing benchmarking under TNMM must be undertaken independently for each assessment year using that year's financial data, even where TNMM is accepted as the most appropriate method. Accordingly, the remand for fresh arm's length price determination remains operative, but the clarification concerning comparative associated-enterprise and non-associated-enterprise segment margins was deleted to remove ambiguity. Case-Laws Income Tax Mon, 19 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471569