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    <title>2025 (2) TMI 1970 - RAJASTHAN HIGH COURT</title>
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    <description>Rectification cannot be used to reopen a final ITAT order that decided the claim on merits and was not further challenged. The Tribunal had already ruled on entitlement to investment allowance for extraction-related plant and machinery, so the issue had attained finality. A later precedent does not, by itself, create a mistake apparent from the record, and a concluded decision cannot be revisited on that basis. The cited circular also did not change the position on the facts. The request to reopen the settled order by rectification was therefore rejected.</description>
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      <description>Rectification cannot be used to reopen a final ITAT order that decided the claim on merits and was not further challenged. The Tribunal had already ruled on entitlement to investment allowance for extraction-related plant and machinery, so the issue had attained finality. A later precedent does not, by itself, create a mistake apparent from the record, and a concluded decision cannot be revisited on that basis. The cited circular also did not change the position on the facts. The request to reopen the settled order by rectification was therefore rejected.</description>
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