HC upheld the Tribunal's refusal to rectify the assessment under s.254(2), concluding the Tribunal's power is confined to correcting mistakes apparent on the record and does not extend to rehearing or reviewing its own decision. No mistake apparent from the record was shown; the assessment dated 24.12.2007, issued after the Appellant's 2005 return and following non-compliance with multiple AO notices, did not cause demonstrable prejudice. The Tribunal and CIT(A) afforded full opportunity to be heard, considered merits across three rounds of litigation, and dismissed the rectification application. Given the Appellant's failure to challenge the Tribunal's 31.10.2019 order on merits, HC declined further relief and dismissed the challenge.
HC upheld the Tribunal's refusal to rectify the assessment under s.254(2), concluding the Tribunal's power is confined to correcting mistakes apparent on the record and does not extend to rehearing or reviewing its own decision. No mistake apparent from the record was shown; the assessment dated 24.12.2007, issued after the Appellant's 2005 return and following non-compliance with multiple AO notices, did not cause demonstrable prejudice. The Tribunal and CIT(A) afforded full opportunity to be heard, considered merits across three rounds of litigation, and dismissed the rectification application. Given the Appellant's failure to challenge the Tribunal's 31.10.2019 order on merits, HC declined further relief and dismissed the challenge.
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