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2019 (4) TMI 500 - AT - Income TaxRectification u/s 254(2) - non-satisfaction or disagreement of the parties to the litigation, with the reasoning given by the Tribunal in its order - HELD THAT:- Commissioner Of Income-Tax vs Ramesh Electric And Trading Co [1992 (11) TMI 32 - BOMBAY HIGH COURT] power of rectification under section 254(2) of the Income-tax Act can be exercised only when the mistake which is sought to be rectified is an obvious and patent; mistake which is apparent from the record, and not a mistake which requires to be established by arguments and a long drawn process of reasoning on points on which there may conceivably be two opinions. Failure by the Tribunal to consider an argument advanced by either party for arriving at a conclusion is not an error apparent on the record, although it may be an error of judgment and under such circumstances the Tribunal has no jurisdiction under section 254(2) to pass the second order.
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