Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Rectification under section 254(2) is confined to obvious, patent and self-evident mistakes on the record, and cannot be used to reopen the merits or seek review of an earlier appellate order. The Tribunal held that the Revenue's complaint of non-consideration of authorities and instructions was, in substance, an attempt to reargue the matter and revisit the decision, not a true rectifiable error. It also noted that a similar contention had already been rejected in an earlier miscellaneous application. The miscellaneous application was therefore found to be without merit and dismissed as an impermissible review request.
Rectification under section 254(2) is confined to obvious, patent and self-evident mistakes on the record, and cannot be used to reopen the merits or seek review of an earlier appellate order. The Tribunal held that the Revenue's complaint of non-consideration of authorities and instructions was, in substance, an attempt to reargue the matter and revisit the decision, not a true rectifiable error. It also noted that a similar contention had already been rejected in an earlier miscellaneous application. The miscellaneous application was therefore found to be without merit and dismissed as an impermissible review request.
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