https://www.taxtmi.com/caselaws?id=799840 Rectification under section 254(2) is confined to a patent, manifest and self-evident mistake apparent from the record. Previously considered seized material, related-party orders, alleged on-money receipts and precedents on income extrapolation cannot be re-examined merely because an assessee disputes their interpretation or asserts factual parity. The provision does not permit reappreciation of evidence, replacement of a possible view, reconsideration of factual findings or review of appeal merits. No mistake apparent from the record arose, so rectification was declined. en-us Thu, 17 Sep 2026 00:00:00 +0530 Mon, 28 Sep 2026 08:12:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799840 Rectification under section 254(2) is confined to a patent, manifest and self-evident mistake apparent from the record. Previously considered seized material, related-party orders, alleged on-money receipts and precedents on income extrapolation cannot be re-examined merely because an assessee disputes their interpretation or asserts factual parity. The provision does not permit reappreciation of evidence, replacement of a possible view, reconsideration of factual findings or review of appeal merits. No mistake apparent from the record arose, so rectification was declined. Case-Laws Income Tax Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799840