https://www.taxtmi.com/caselaws?id=471312 Rectification under section 254(2) applies where an order contains an error apparent from the record. Penalties for the two assessment years arose from distinct additions-interest in one year and prior-period expenses in the other-so applying findings from the former year mutatis mutandis to the latter constituted a manifest factual error. The rectification application was treated as timely under liberty granted by the High Court, with delay otherwise condoned. The earlier order was recalled to the extent concerning the later assessment year, and the appeal was restored for fresh hearing. en-us Fri, 07 Jun 2024 00:00:00 +0530 Sat, 29 Aug 2026 10:53:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471312 Rectification under section 254(2) applies where an order contains an error apparent from the record. Penalties for the two assessment years arose from distinct additions-interest in one year and prior-period expenses in the other-so applying findings from the former year mutatis mutandis to the latter constituted a manifest factual error. The rectification application was treated as timely under liberty granted by the High Court, with delay otherwise condoned. The earlier order was recalled to the extent concerning the later assessment year, and the appeal was restored for fresh hearing. Case-Laws Income Tax Fri, 07 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471312