2025 (5) TMI 890

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... : Shri B.P. Srivastava, Sr.DR ORDER PER MAKARAND V.MAHADEOKAR, AM: The present Miscellaneous Application has been filed by the assessee under section 254(2) of the Income Tax Act, 1961 seeking rectification of the order passed by this Co-ordinate Bench in ITA No. 2193/Ahd/2024 dated 25.03.2025. It is the contention of the assessee that certain submissions and factual aspects were not appropria .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... sufficient opportunities during the assessment proceedings but failed to respond within the time permitted. It was further submitted that the Tribunal, after appreciating all material on record, has passed a reasoned order restoring the matter to the CIT(A) for fresh adjudication. The learned DR also submitted that since the CIT(A) possesses coterminous powers with the AO and can call for remand r .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... d manifest from the record. A review or reconsideration of reasoning or conclusion reached in the appellate order cannot be undertaken in the garb of rectification. 5. The Bench in para 5 and 7 of the order has already recorded a categorical finding that the appeal before the CIT(A) was dismissed in limine without deciding the grounds on merits, and that there was no speaking order passed on any .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X