Appellate Tribunal Can Amend Tax Appeal Orders Under Section 254; Rectification Allowed Within Six Months Post-Notification

The Appellate Tribunal, under Section 254, is empowered to pass orders after hearing both parties in an income tax appeal. It can amend orders within six months to rectify apparent mistakes if notified by the assessee or the Assessing Officer. Amendments increasing the assessee's liability require prior notice and a hearing. Appeals should ideally be resolved within four years, with a stay of proceedings granted for up to 180 days, extendable to a maximum of 365 days. The Tribunal's decisions are final unless appealed under Section 260A. On factual issues, a writ petition can challenge the Tribunal's fact-finding process in higher courts.

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