Rectification under section 254(2) is limited to apparent errors, while an omitted ground may justify recall for limited adjudication.

Section 254(2) permits rectification only of manifest clerical or factual mistakes, not reconsideration of substantive reasoning on issues such as the relationship between the parties, the nature of advertisement airtime, or transfer pricing and treaty analysis. The Tribunal therefore corrected only clear record errors, including the description of channel ownership, dates in the cause title, and an erroneous sentence, while leaving the substantive reasoning unchanged. Where a ground in one appeal had not been adjudicated, the omission was treated as an apparent error requiring recall only to the limited extent necessary to decide that ground. The substantive findings otherwise remained undisturbed.

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Issues: (i) Whether the order of the Tribunal suffered from mistakes apparent from record warranting rectification under section 254(2) of the Income-tax Act, 1961 in respect of the recorded facts, hearing details, observations on the nature of advertisement airtime, and related reasoning. (ii) Whether the omission to adjudicate Ground No. 6 in one of the appeals called for recall of the order for limited purposes.

Issue (i): Whether the order of the Tribunal suffered from mistakes apparent from record warranting rectification under section 254(2) of the Income-tax Act, 1961 in respect of the recorded facts, hearing details, observations on the nature of advertisement airtime, and related reasoning.

Analysis: The Tribunal accepted only those corrections that were clearly clerical or factual in nature, such as the incorrect description of the channel ownership, the dates shown in the cause title, and an erroneous sentence on page 25. It declined to interfere with the substantive reasoning because the impugned observations reflected a conscious view on the nature of the relationship between the assessee and NGC India, the character of advertisement airtime, and the treatment of the transfer pricing and treaty issues. Such matters did not amount to an apparent mistake capable of rectification under section 254(2).

Conclusion: Rectification was allowed only to the limited extent of correcting manifest factual and clerical errors, and the substantive challenge was rejected.

Issue (ii): Whether the omission to adjudicate Ground No. 6 in one of the appeals called for recall of the order for limited purposes.

Analysis: The Tribunal found that Ground No. 6 had not been adjudicated in the appeal relating to assessment year 2008-09. Since non-disposal of a ground constitutes an omission apparent from the record, the order required recall only to that limited extent and not for reopening the entire matter.

Conclusion: The order was recalled solely for disposing of Ground No. 6 in the relevant appeal.

Final Conclusion: The miscellaneous applications succeeded only in part, with limited rectification of apparent errors and a restricted recall for an unadjudicated ground, while the substantive findings remained undisturbed.

Ratio Decidendi: Section 254(2) permits correction only of apparent, non-debatable mistakes and not reconsideration of substantive conclusions, but an omitted ground requires recall to the limited extent necessary for adjudication.

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