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The Tax PublishersMP No. 92/Bang/2020 (in IT(PT)A No. 1529/Bang/2014)
2020 TaxPub(DT) 5203 (Bang-Trib)INCOME TAX ACT 1961
Section 254(2)
There was no apparent mistake in the impugned Tribunal order which can be rectified under section 254(2) as only contention raised by assessee was that the Tribunal was not correct in saying that no argument was advanced regarding transfer pricing adjustments in both the R&D and Lithium segments.
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Appeal (Tribunal) - Rectification under section 254(2) - No mistake apparent from record -
Assessee filed miscellaneous petition stating that there were certain apparent mistakes in the impugned Tribunal order which should be rectified under section 254(2) in respect of transfer pricing adjustments in both the R&D and Lithium segments. Held: It was seen that there was no apparent mistake in the impugned Tribunal order which can be rectified under section 254(2) because this was the only contention raised by assessee that the Tribunal was not correct in saying that no argument was advanced in respect of transfer pricing adjustment in both the R&D and Lithium segments and in fact, no evidence could be brought on record by assessee in this regard to establish that arguments were in fact advanced.
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
IN THE ITAT, BANGALORE BENCH
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