TMI Blog2001 (5) TMI 17X X X X Extracts X X X X X X X X Extracts X X X X ..... led by the appellant under section 254 of the Income-tax Act, 1961. The appellant filed a return of income showing income from profession at Rs.11,276 and interest income was shown at Rs.14,538. The Assistant Commissioner of Income-tax assessed the income at Rs.3,34,614. An appeal was filed before the Commissioner of Income-tax (Appeals). The appellant submitted that the Hindu undivided family ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8, to that effect that: "The assessee has claimed the FDRs belonging to his married daughter. However, he has filed no evidence to support this contention. He even did not file the confirmation from the daughter claiming the ownership of such FDR. At the time of hearing before us, the only contention put forth by learned counsel for the assessee was that the FDR pertains to earlier years. Howeve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 254(2) a rectification application can lie only with respect to an error apparent on the face of the record. We find that various reasons were adopted by the Income-tax Appellate Tribunal to make the addition of Rs.5,500 which we have quoted above. The scope of rectification proceedings is very limited and is narrower than the proceedings for review. The Tribunal has also found that the evidence ..... X X X X Extracts X X X X X X X X Extracts X X X X
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