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    <title>2022 (11) TMI 1497 - KARNATAKA HIGH COURT</title>
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    <description>A second appellate authority cannot use rectification proceedings to reopen a reassessment order that has attained finality. The rectification application was limited to alleged mistakes apparent from the record, and the first appellate authority had already found no such mistake. In second appeal, the Tribunal was required to test only the correctness of the order refusing rectification; it could not expand the dispute, reassess evidence, or examine issues such as seized documents or turnover discrepancies that fell outside rectification. Those grievances could be raised only in a regular appeal. The Tribunal&#039;s remand was therefore impermissible and the issue was answered against the assessee.</description>
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    <pubDate>Fri, 25 Nov 2022 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=456340</link>
      <description>A second appellate authority cannot use rectification proceedings to reopen a reassessment order that has attained finality. The rectification application was limited to alleged mistakes apparent from the record, and the first appellate authority had already found no such mistake. In second appeal, the Tribunal was required to test only the correctness of the order refusing rectification; it could not expand the dispute, reassess evidence, or examine issues such as seized documents or turnover discrepancies that fell outside rectification. Those grievances could be raised only in a regular appeal. The Tribunal&#039;s remand was therefore impermissible and the issue was answered against the assessee.</description>
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