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2020 (2) TMI 414 - AT - Income TaxRectification of mistake u/s 154 - characterisation of income - HELD THAT:- This fact is very much noted by the Assessing Officer that the date of Agreement itself is not in the period relevant to the Asst. Year in question. But even after noting this aspect of the matter, addition was not made by him on the basis of date of Agreement but on the basis that the amount in question is capital in nature. Hence the contention raised in the present M.P. that there is apparent mistake in the Tribunal order because the Tribunal has not considered the date of Agreement is devoid of any merit. Under these facts and circumstances, we hold that there is no mistake apparent in the Tribunal order on this aspect.
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