https://www.taxtmi.com/caselaws?id=341543 Rectification under section 154 of the Income-tax Act is limited to mistakes apparent from the record, meaning clear and patent errors existing when the original order was passed. A later Special Bench decision cannot be used to treat an earlier appellate order as or open it to rectification if that later view was not available at the time. The CBDT circular relied on was held inapplicable because it addressed subsequent interpretation by the Supreme Court, not a later Tribunal ruling. The proposed rectification was therefore an impermissible indirect challenge to the earlier order, and the Revenue's attempt failed. en-us Fri, 07 Apr 2017 00:00:00 +0530 Wed, 12 Apr 2017 06:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341543 Rectification under section 154 of the Income-tax Act is limited to mistakes apparent from the record, meaning clear and patent errors existing when the original order was passed. A later Special Bench decision cannot be used to treat an earlier appellate order as or open it to rectification if that later view was not available at the time. The CBDT circular relied on was held inapplicable because it addressed subsequent interpretation by the Supreme Court, not a later Tribunal ruling. The proposed rectification was therefore an impermissible indirect challenge to the earlier order, and the Revenue's attempt failed. Case-Laws Income Tax Fri, 07 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341543