Section 254(2) Limits: Rectification Only for Clear Errors, Not Tribunal Dissatisfaction or Decision Review.

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....Rectification of mistake u/s 254 - If such prayer is allowed then in every case, where the assessee is not satisfied with the finding of the Tribunal, the MA will be filed. In our considered view, powers u/s 254(2) are very limited which could only be exercised to rectify any mistake or fact apparent from the record. But, where the Tribunal has applied its mind and comes to a particular conclusion then disturbing such finding would tantamount to review the order - AT....