https://www.taxtmi.com/caselaws?id=471498 Rectification under Section 254(2) is confined to a patent mistake apparent from the record and cannot be used to review a reasoned appellate decision. A writ order that declined interference during pending assessment proceedings, left all pleas open before the Assessing Officer, and preserved the right to challenge an adverse assessment contains no merits determination on the special-audit reference or limitation. Objections to admission of an additional ground, the Tribunal's jurisdiction to examine the special-audit reference for limitation, and prior findings seek reconsideration of decided matters. As no apparent mistake was established, rectification was unavailable; the proper remedy was statutory appeal. en-us Fri, 09 Aug 2024 00:00:00 +0530 Mon, 07 Sep 2026 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471498 Rectification under Section 254(2) is confined to a patent mistake apparent from the record and cannot be used to review a reasoned appellate decision. A writ order that declined interference during pending assessment proceedings, left all pleas open before the Assessing Officer, and preserved the right to challenge an adverse assessment contains no merits determination on the special-audit reference or limitation. Objections to admission of an additional ground, the Tribunal's jurisdiction to examine the special-audit reference for limitation, and prior findings seek reconsideration of decided matters. As no apparent mistake was established, rectification was unavailable; the proper remedy was statutory appeal. Case-Laws Income Tax Fri, 09 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471498