Rectification jurisdiction bars evidence reappraisal where alleged on-money additions were previously decided after considering relevant material.
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....Rectification jurisdiction permits correction only of a patent, manifest or self-evident error, not reassessment of evidence or review of an earlier view. Claims that additions for alleged on-money receipts failed to consider seized material, related orders, a co-ordinate Bench decision and precedents on income extrapolation did not establish a mistake apparent from the record where those materials had been considered. The rectification applications therefore amounted to an impermissible review and were dismissed.....
TaxTMI