Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
ITAT rejected Revenue's application for rectification under Section 254(2). The Tribunal determined that the application was essentially a disguised attempt to review the original order, which is impermissible. The Tribunal emphasized that its power under Section 254(2) is limited to correcting apparent mistakes on the record, not re-examining the merits of the case. Relying on precedent, the Tribunal held that revisiting the original order's substantive findings falls outside the scope of Section 254(2). Consequently, the Miscellaneous Application was dismissed, with the Tribunal maintaining its original order and finding no mistake apparent on the record warranting rectification.
ITAT rejected Revenue's application for rectification under Section 254(2). The Tribunal determined that the application was essentially a disguised attempt to review the original order, which is impermissible. The Tribunal emphasized that its power under Section 254(2) is limited to correcting apparent mistakes on the record, not re-examining the merits of the case. Relying on precedent, the Tribunal held that revisiting the original order's substantive findings falls outside the scope of Section 254(2). Consequently, the Miscellaneous Application was dismissed, with the Tribunal maintaining its original order and finding no mistake apparent on the record warranting rectification.
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