https://www.taxtmi.com/caselaws?id=468753 A rectificatory application was held maintainable where the earlier order had omitted to decide a raised legal plea that reopening beyond four years was invalid absent failure to disclose fully and truly material facts; the omission was treated as an apparent mistake, and the reassessment challenge was restored for adjudication. The application was also allowed on the section 68 issue because material evidence on the nature and source of share capital and share premium, including documents, remand material, the shareholders' agreement, investor status and comparable treatment in other years, had not been considered. The Tribunal emphasised that rectification may correct an apparent mistake caused by overlooking material issues or evidence, but cannot be used as a review. en-us Thu, 20 Nov 2025 00:00:00 +0530 Tue, 19 May 2026 13:11:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468753 A rectificatory application was held maintainable where the earlier order had omitted to decide a raised legal plea that reopening beyond four years was invalid absent failure to disclose fully and truly material facts; the omission was treated as an apparent mistake, and the reassessment challenge was restored for adjudication. The application was also allowed on the section 68 issue because material evidence on the nature and source of share capital and share premium, including documents, remand material, the shareholders' agreement, investor status and comparable treatment in other years, had not been considered. The Tribunal emphasised that rectification may correct an apparent mistake caused by overlooking material issues or evidence, but cannot be used as a review. Case-Laws Income Tax Thu, 20 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468753