2022 (7) TMI 859

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.... For the Respondent : Shri M.K. Jain, Sr.DR ORDER PER PRADIP KUMAR KEDIA, A.M.: The captioned appeal has been filed at the instance of the assessee against the order of the Commissioner of Income Tax (Appeals)-V, New Delhi ['CIT(A)' in short] dated 30.01.2015 arising from the assessment order dated 31.01.2014 passed by the Assessing Officer (AO) under Section 143(3) r.w. Section 92CA of t....

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....t of the appellate order for A.Y. 2010-11 in which you claimed to have raised additional ground of appeal. It is noted from your application that the impugned order is not a speaking order. In fact, therefore, your application requires reconsideration of the entire matter and is not covered under the purview of mistake apparent from record. Your application is thus rejected." 4. On perusal of t....

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....e CIT(A) has disposed of the rectification application against the assessee on the ground that such alleged error requires reconsideration of the entire matter and cannot be bracketed in the category of mistake apparent from record. 5. We endorse the view taken by the CIT(A) on the touchstone of limited scope of Section 154 of the Act. In the absence of relevant facts emerging from records corr....