https://www.taxtmi.com/caselaws?id=759193 ITAT Allahabad dismissed miscellaneous applications filed by assessee under section 254(2) seeking rectification of tribunal's order. The assessee attempted to raise new issues regarding jurisdictional defects in reassessment notices under section 148, which were not raised during original appeal proceedings. The tribunal held that section 254(2) provisions exist only for rectifying mistakes in ITAT's own orders, not for providing second opportunity to raise omitted issues or for considering new facts/legal points. Since no mistake existed in ITAT's order when issues were never agitated before it, all miscellaneous applications were dismissed as non-maintainable. en-us Fri, 09 Aug 2024 00:00:00 +0530 Wed, 25 Sep 2024 10:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759193 ITAT Allahabad dismissed miscellaneous applications filed by assessee under section 254(2) seeking rectification of tribunal's order. The assessee attempted to raise new issues regarding jurisdictional defects in reassessment notices under section 148, which were not raised during original appeal proceedings. The tribunal held that section 254(2) provisions exist only for rectifying mistakes in ITAT's own orders, not for providing second opportunity to raise omitted issues or for considering new facts/legal points. Since no mistake existed in ITAT's order when issues were never agitated before it, all miscellaneous applications were dismissed as non-maintainable. Case-Laws Income Tax Fri, 09 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759193