Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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ITAT dismissed the assessee's miscellaneous application seeking rectification under section 254(2). The tribunal held that the application was essentially attempting to review the original order, which is impermissible under law. Established judicial precedent confirms that review disguised as rectification is not allowed. An oversight of fact or failure to consider an argument does not constitute an apparent mistake rectifiable under the provision. The tribunal's original findings on section 69A and 115BBE remained unchanged, and the application was rejected on procedural grounds, maintaining the integrity of the original appellate order.
ITAT dismissed the assessee's miscellaneous application seeking rectification under section 254(2). The tribunal held that the application was essentially attempting to review the original order, which is impermissible under law. Established judicial precedent confirms that review disguised as rectification is not allowed. An oversight of fact or failure to consider an argument does not constitute an apparent mistake rectifiable under the provision. The tribunal's original findings on section 69A and 115BBE remained unchanged, and the application was rejected on procedural grounds, maintaining the integrity of the original appellate order.
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