INCOME TAX ACT, 1961

Section 254(2)

Rectification under section 254(2) - No mistake apparent - Finding of fact recorded by ITAT after considering various submissions and evidences -

Assessee By way of Miscellaneous Applications, sought rectification under section 254(2) as regards transfer pricing adjustment of export of FDF to AE. Assessee's case was that various submissions and evidence has not been properly appreciated. by ITAT. Held: It was in fact an admission on the part of assessee that prices charged from associated enterprise were comparatively lower, which in turn further fortified the action of TPO. It was contention of assessee that AO has not given effect to the direction of DRP regarding adjustment in ALP computed by directed AO to follow direction of DRP. Thus, finding of the fact were recorded by Tribunal after considering submissions and perusing the record. What assessee was seeking was clearly review of the order not permissible under section 254(2). Hence, miscellaneous application was dismissed as such.

REFERRED :

FAVOUR : Against the assessee.

A.Y. :

INCOME TAX ACT, 19612

Section 254(2)

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