Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Rectification under section 254(2) is confined to a patent, obvious error apparent from the record and cannot be used to reargue debatable issues, reassess evidence, or reopen the merits of an earlier time-bar dismissal. The High Court held that complaints about the Tribunal's failure to summon further material, its treatment of the driver's affidavit on delay condonation, and alleged non-consideration of precedent involved adjudicatory choice rather than self-evident error, so no rectifiable mistake was shown. In the section 260A appeal, interference was unavailable absent perversity or a substantial question of law. The appeals were dismissed.
Rectification under section 254(2) is confined to a patent, obvious error apparent from the record and cannot be used to reargue debatable issues, reassess evidence, or reopen the merits of an earlier time-bar dismissal. The High Court held that complaints about the Tribunal's failure to summon further material, its treatment of the driver's affidavit on delay condonation, and alleged non-consideration of precedent involved adjudicatory choice rather than self-evident error, so no rectifiable mistake was shown. In the section 260A appeal, interference was unavailable absent perversity or a substantial question of law. The appeals were dismissed.
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