https://www.taxtmi.com/caselaws?id=778548 The dominant issue was whether the ITAT could invoke rectification power under s.254(2) of the IT Act to alter its earlier order solely because a later SC judgment changed the legal position. Relying on the analogy to review under O.47 r.1 CPC and its Explanation, as affirmed by SC, the HC held that a subsequent reversal or change in law is not a "mistake apparent from the record" and cannot found rectification jurisdiction under s.254(2). Consequently, the ITAT's rectification order was set aside; as a corollary, the ITAT's earlier appellate order under s.254(1) dismissing the appeal was also set aside. en-us Fri, 12 Sep 2025 00:00:00 +0530 Tue, 24 Mar 2026 15:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778548 The dominant issue was whether the ITAT could invoke rectification power under s.254(2) of the IT Act to alter its earlier order solely because a later SC judgment changed the legal position. Relying on the analogy to review under O.47 r.1 CPC and its Explanation, as affirmed by SC, the HC held that a subsequent reversal or change in law is not a "mistake apparent from the record" and cannot found rectification jurisdiction under s.254(2). Consequently, the ITAT's rectification order was set aside; as a corollary, the ITAT's earlier appellate order under s.254(1) dismissing the appeal was also set aside. Case-Laws Income Tax Fri, 12 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778548