Rectification of apparent mistakes excludes merits review but permits correction of an omitted TDS-credit claim after verification.
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....Rectification for a mistake apparent from the record is limited to patent, manifest and self-evident errors identifiable without prolonged reasoning. Detailed challenges to remand directions on an AMP transfer-pricing adjustment or an associated-enterprise share purchase seek a review on merits and fall outside section 254(2); those rectification requests fail. Omission to decide an unrebutted claim for TDS credit constitutes a rectifiable omission. Supporting evidence requires verification before TDS credit is granted in accordance with law, while the remaining rectification claims do not survive.....
TaxTMI