ITAT decision errors aren't rectifiable u/s 254(2); appeal to High Court for relief on Section 271(1)(c) penalties.

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....Rectification u/s 254 - Penalty u/s 271(1)(c) was deleted - Without prejudice to the above, assuming the findings of the ITAT is not correct than it would not amount to a mistake apparent from record which could be rectified under the provision of section 254(2) of the Act. If the decision of the ITAT is wrong than the aggrieved parties can approach to the Higher Judicial forum i.e. Jurisdictional High Court. But such findings cannot be rectified on the reasoning that there is a mistake apparent from the record. If we do so it would amount to review its own order by the ITAT which is not permissible. - AT....