https://www.taxtmi.com/caselaws?id=782535 HC held that ITAT exceeded its limited rectification jurisdiction under s. 254(2) by reappreciating evidence and effectively sitting in appeal over its own earlier order dated 21.09.2011. Rectification is confined to mistakes apparent on the face of the record and cannot be used to revisit the merits or review an erroneous order, which lies only in appeal. The rectification order dated 26.03.2013, by which ITAT recalled the 5% profit rate and redetermined income at 50% of the original assessment, was found perverse and without jurisdiction. HC set aside the rectification order and restored the original ITAT order dated 21.09.2011. en-us Thu, 27 Nov 2025 00:00:00 +0530 Mon, 01 Dec 2025 08:50:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782535 HC held that ITAT exceeded its limited rectification jurisdiction under s. 254(2) by reappreciating evidence and effectively sitting in appeal over its own earlier order dated 21.09.2011. Rectification is confined to mistakes apparent on the face of the record and cannot be used to revisit the merits or review an erroneous order, which lies only in appeal. The rectification order dated 26.03.2013, by which ITAT recalled the 5% profit rate and redetermined income at 50% of the original assessment, was found perverse and without jurisdiction. HC set aside the rectification order and restored the original ITAT order dated 21.09.2011. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782535