https://www.taxtmi.com/caselaws?id=65433 The Tribunal treated the assessee's objections as mistakes apparent from the record under section 254(2) because the earlier order proceeded on an unsupported factual assumption that expatriate salaries deputed for ONGC drilling contracts had been claimed as deductions under section 44BB. That mistaken premise affected the conclusion that Article XIV(2)(c) of the treaty was not satisfied. As the errors were factual and went to the basis of the earlier reasoning, recall was considered appropriate rather than a merits-based review, and the matter was directed to be heard afresh. en-us Fri, 21 Oct 2005 00:00:00 +0530 Tue, 15 Feb 2011 16:32:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65433 The Tribunal treated the assessee's objections as mistakes apparent from the record under section 254(2) because the earlier order proceeded on an unsupported factual assumption that expatriate salaries deputed for ONGC drilling contracts had been claimed as deductions under section 44BB. That mistaken premise affected the conclusion that Article XIV(2)(c) of the treaty was not satisfied. As the errors were factual and went to the basis of the earlier reasoning, recall was considered appropriate rather than a merits-based review, and the matter was directed to be heard afresh. Case-Laws Income Tax Fri, 21 Oct 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65433