https://www.taxtmi.com/caselaws?id=467582 Section 254(2) permits only rectification of a patent mistake apparent from the record and cannot be used to reopen the merits or conduct a review. The Tribunal held that the Revenue's reliance on a later Supreme Court ruling did not show any such mistake, because the earlier order had already examined the jurisdictional and limitation issues on the facts and law available at the time. Since the later ruling was not available when the matter was heard, its omission did not justify recall or rectification. The proper remedy for any perceived error lay in appeal, so the miscellaneous application failed. en-us Wed, 04 Feb 2026 00:00:00 +0530 Tue, 24 Mar 2026 19:07:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467582 Section 254(2) permits only rectification of a patent mistake apparent from the record and cannot be used to reopen the merits or conduct a review. The Tribunal held that the Revenue's reliance on a later Supreme Court ruling did not show any such mistake, because the earlier order had already examined the jurisdictional and limitation issues on the facts and law available at the time. Since the later ruling was not available when the matter was heard, its omission did not justify recall or rectification. The proper remedy for any perceived error lay in appeal, so the miscellaneous application failed. Case-Laws Income Tax Wed, 04 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467582