Issue decided on merit cannot be construed as decided on the basis of mistake apparent from record

RELEVANT PARAGRAPH

It is evident that both the issues raised by the assessee in the present miscellaneous application were decided by the Bench, on merit and having regard to the rival submissions and case laws relied upon by the assessee, in respect of relevant issue, as discussed earlier. Thus, both the issues are debatable and susptible to different opinions. These issues decided on merit after appreciation of the facts of the case, as highlighted in the impu

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