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    <title>2018 (10) TMI 1514 - DELHI HIGH COURT</title>
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    <description>Rectification under Section 254(2) is confined to correcting an apparent mistake and cannot be used for rehearing on merits; the Tribunal&#039;s refusal to rectify was upheld because the alleged omission involved appreciation of facts and evidence, not a recordable error. On taxability of lease rentals under the agreement dated 31.03.2008, the arrangement was treated as only an assignment of income, not a transfer of the source of income, because ownership of the asset remained with the hotel company and the right to receive rent was finite and revocable. The rental income was therefore assessed in the hands of the owner, and the challenge failed.</description>
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      <description>Rectification under Section 254(2) is confined to correcting an apparent mistake and cannot be used for rehearing on merits; the Tribunal&#039;s refusal to rectify was upheld because the alleged omission involved appreciation of facts and evidence, not a recordable error. On taxability of lease rentals under the agreement dated 31.03.2008, the arrangement was treated as only an assignment of income, not a transfer of the source of income, because ownership of the asset remained with the hotel company and the right to receive rent was finite and revocable. The rental income was therefore assessed in the hands of the owner, and the challenge failed.</description>
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