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of <h1>Section 254(2) and Order XLVII Rule 1 CPC limit recalls to correcting record mistakes; later overrulings alone don't suffice</h1> The court held that the tribunal's power under Section 254(2) is limited to correcting mistakes apparent on the record as of the original order and cannot be invoked solely because a superior court later changed or clarified the law; a prior binding decision not placed before the tribunal may justify recall, but a subsequent overruling does not. The decision distinguished earlier authority relied on by revenue as fact-specific, affirmed that Section 254(2) parallels Order XLVII Rule 1 CPC's narrow review scope, set aside the tribunal's recall based on a later ruling, and noted the revenue retains ordinary appellate remedies where available.
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