Rectification Sought for Transfer Pricing Adjustment; Rule 13 Requires Apparent Mistake in DRP Directions for Jurisdiction.

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....Rectification of mistake u/s 154 - TP Adjustment - arm's length price adjustment - even after holding that there was no apparent mistake in the DRP directions, whereas a finding of the mistake being a mistake apparent in the DRP directions was a sine qua non for invoking the jurisdiction under rule 13. - AT....