https://www.taxtmi.com/caselaws?id=310718 ITAT Ahmedabad dismissed Revenue's miscellaneous application seeking rectification under section 254. Revenue challenged ITAT's findings on validity of reopening assessment, holding that reason to believe was recorded without application of mind, and that additions under section 153A require incriminating material found during search. ITAT held no apparent mistake existed in its order, noting Revenue's arguments required elaborate discussion not permissible under section 254(2). ITAT emphasized that if Revenue considers order erroneous on law or facts, remedy lies in appeal to HC, not rectification. en-us Wed, 24 Aug 2022 00:00:00 +0530 Thu, 09 Nov 2023 08:51:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310718 ITAT Ahmedabad dismissed Revenue's miscellaneous application seeking rectification under section 254. Revenue challenged ITAT's findings on validity of reopening assessment, holding that reason to believe was recorded without application of mind, and that additions under section 153A require incriminating material found during search. ITAT held no apparent mistake existed in its order, noting Revenue's arguments required elaborate discussion not permissible under section 254(2). ITAT emphasized that if Revenue considers order erroneous on law or facts, remedy lies in appeal to HC, not rectification. Case-Laws Income Tax Wed, 24 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310718