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Tribunal's Order Unaffected by CBDT Circular Due to Unavailability During Hearing; No Rectification u/s 254(2) Possible.

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....Rectification u/s 254 - Maintainability of appeal on low tax effect - both CBDT Circular no. 23 of 2019 and special order dated 16.09.2019 were not in existence and thus not part of the record at the time when the matter was heard on 20.08.2019 or at the time of passing of order by the Tribunal on 22.08.2019 and therefore, non-consideration of subsequent CBDT Circular and the special order so passed by the CBDT is not a mistake apparent from record which can be rectified within the narrow compass of section 254(2) of the Act. - AT....

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Tribunal's Order Unaffected by CBDT Circular Due to Unavailability During Hearing; No Rectification u/s 254(2) Possible.