https://www.taxtmi.com/caselaws?id=776348 A Miscellaneous Application under section 254(2) cannot be used to seek review or reconsideration of a concluded ITAT order unless a patent mistake apparent from the record is shown. The Tribunal found that its earlier decision had already considered the effect of a registered development agreement cum GPA and the authorities governing the year of taxability of capital gains. The applicant's grievance merely sought re-argument of the merits, which is impermissible in rectification proceedings. Relief relating to tax allegedly paid for a different assessment year was also refused as outside the scope of the dispute. The rectification petition was rejected and the earlier appellate order remained undisturbed. en-us Thu, 31 Jul 2025 00:00:00 +0530 Fri, 08 Aug 2025 05:20:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776348 A Miscellaneous Application under section 254(2) cannot be used to seek review or reconsideration of a concluded ITAT order unless a patent mistake apparent from the record is shown. The Tribunal found that its earlier decision had already considered the effect of a registered development agreement cum GPA and the authorities governing the year of taxability of capital gains. The applicant's grievance merely sought re-argument of the merits, which is impermissible in rectification proceedings. Relief relating to tax allegedly paid for a different assessment year was also refused as outside the scope of the dispute. The rectification petition was rejected and the earlier appellate order remained undisturbed. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776348