TMI Blog2020 (10) TMI 833X X X X Extracts X X X X X X X X Extracts X X X X ..... itional facts and evidences stating that the Tribunal has erred in not taking note of these additional facts and evidences - HELD THAT:- DR could not point out any mistake in the impugned order which can be said to be a mistake apparent from record. In fact, the Department through these applications seeks the review of the order by way of pleading additional facts which is not permissible in a rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... led to point out what fact or even any argument coming from record, the Tribunal has failed to consider in the order dated 12.7.2019. - Decided against revenue. - M.A. No.3 to 7 /Chd/2020 (Arising out of ITA Nos. 1240 , 1238, 1239, 1241, 1242 / Chd / 2018 ) - - - Dated:- 6-10-2020 - SHRI N.K. SAINI, VICE PRESIDENT And SHRI SANJAY GARG, JUDICIAL ME MBER Appellant By : Shri Lalit Bishnoi, J ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... caped attention of the Tribunal. The Ld. DR could not point out any mistake in the impugned order which can be said to be a mistake apparent from record. In fact, the Department through these applications seeks the review of the order by way of pleading additional facts which is not permissible in a rectification application u/s 254(2) of the Income Tax Act, 1961. This Tribunal does not have any p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ised 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. Even failure by the Tribunal to consider an argument advanced by either party for arriving at a conclusion is no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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