https://www.taxtmi.com/caselaws?id=463683 ITAT (Surat) held that section 254(2) permits only correction of mistakes that are ex facie and incapable of argument; it does not allow reappraisal of facts, correction of errors of law, or reopening matters that require fresh hearing. Failure to consider an argument is an error of judgment, not an apparent mistake on the record. An application framed as rectification cannot be used to re-argue or substitute the Tribunal's original order. Consequently, the assessee's miscellaneous applications under section 254(2) were dismissed for lack of any mistake apparent on the record. en-us Mon, 14 Aug 2023 00:00:00 +0530 Mon, 08 Sep 2025 12:11:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463683 ITAT (Surat) held that section 254(2) permits only correction of mistakes that are ex facie and incapable of argument; it does not allow reappraisal of facts, correction of errors of law, or reopening matters that require fresh hearing. Failure to consider an argument is an error of judgment, not an apparent mistake on the record. An application framed as rectification cannot be used to re-argue or substitute the Tribunal's original order. Consequently, the assessee's miscellaneous applications under section 254(2) were dismissed for lack of any mistake apparent on the record. Case-Laws Income Tax Mon, 14 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463683