2001 (5) TMI 17

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.... has been filed against the order of the Income-tax Appellate Tribunal rejecting an application filed by the appellant under section 254 of the Income-tax Act, 1961. The appellant filed a return of income showing income from profession at Rs.11,276 and interest income was shown at Rs.14,538. The Assistant Commissioner of Income-tax assessed the income at Rs.3,34,614. An appeal was filed before ....

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....ect to the F.D.R. of Rs.5,500. The Tribunal arrived at a finding in the order dated December 8, 1998, to that effect that: "The assessee has claimed the FDRs belonging to his married daughter. However, he has filed no evidence to support this contention. He even did not file the confirmation from the daughter claiming the ownership of such FDR. At the time of hearing before us, the only content....

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.... is that a case for rectification was made out with respect to the FDR of Rs.5,500. Under section 254(2) a rectification application can lie only with respect to an error apparent on the face of the record. We find that various reasons were adopted by the Income-tax Appellate Tribunal to make the addition of Rs.5,500 which we have quoted above. The scope of rectification proceedings is very ....