Only ‘mistake apparent from record’ can be rectified U/s. 254 (2)

ÍTO Vs Devendra J Kothari (ITAT Ahmedabad)

Conclusion: High Court faulted the Tribunal’s decision of reducing the penalty as a ‘way to bypass the minimum limit’ and the Tribunal was in error in granting the relief, the same does not constitute a mistake apparent from the record so as to enable the Tribunal to revisit its decision

Facts –

AO added INR 43,72,650 as unexplained investment and imposed pe

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