Mere citing of Law laid down by SC before tribunal and non application of same cannot be said mistake apparent from the record

RELEVANT PARAGRAPH 7. Ld. Sr. Counsel appearing for the assessee has contended that the Tribunal in its appellate order has cited two Supreme Court decisions in Royal Hatcheries V. State of Andhra Pradesh. AIR 1994 SC 666 and in M/s.Sil Import USA Vs. M/s.Exim Aides Silk Exporters, AIR 1999 SC 1609, 1612-13, without confronting the assessee at the time of hearing of the appeal before the Tribunal, and therefore, it amounts to mistake apparent from the record in the order of the Tribunal. We for the sake of clarity reproduce the relevant portions of the order of the Tribunal wherein these two d...