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2020 (11) TMI 254 - ITAT BANGALORERectification u/s 254 - scope of the proceedings before the AO pursuant to the two set of orders passed u/s.263 - HELD THAT:- Delay in filing the appeal is not condoned, there is no necessity or need to give any finding on the merits of the appeal. Though there is merit in the contention of the learned counsel for the Assessee regarding the scope of proceedings while passing the set of revisionary orders u/s.263 of the Act dated 16.1.2017, since the delay in filing the appeals were not condoned, there was no scope for giving any findings on scope of proceedings u/s.263 of the Act or recording any observations made at the time of hearing on the first set of orders u/s.263 of the Act dated 24.3.2014. In other words, those aspects did not require any consideration. The scope of proceedings u/s.254(2) of the Act are very limited to rectifying mistakes that are apparent on the face of the record. There is no such apparent mistake in the order of the Tribunal pointed out in these petitions. In the given circumstances, we are of the view that the order of the Tribunal does not suffer from any mistake apparent on the face of the record. We dismiss the miscellaneous petitions filed by the assessee.
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