TaxTMI 
TaxTMI 
2019 (9) TMI 919
X X X X Extracts X X X X
X X X X Extracts X X X X
....ali Mohan Rao For the Revenue : Sri Y.V.S.T. Sai, CIT-DR ORDER PER SMT. P. MADHAVI DEVI, J.M. These miscellaneous applications are filed by the assessee for the rectification of alleged mistakes in the order of the Tribunal for the A.Ys 2013-14 & 2014-15 respectively. 2. In M.A. No.66/Hyd/2019, the assessee has submitted that one of the issues in the appeal is regarding Arms' Length Adjustmen....
X X X X Extracts X X X X
X X X X Extracts X X X X
....al average, should be charged with interest based on the rate of LIBOR since it is an international transaction. He, therefore, submitted that the Tribunal has already considered this issue and there was no mistake apparent from the record which needs any rectification u/s 254(2) of the Act. 4. Having regard to the rival contentions and the material on record, we find that one of the issues in th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....r the merits of the additional grounds of appeal filed by the assessee. If these grounds are admitted and allowed, then the consequences/result of such decision would have an impact on the decision already taken by the Tribunal. Therefore, these grounds may need adjudication by the Tribunal. Therefore, we are of the opinion that there is a mistake apparent from the record which needs rectification....