Change in Law or Judgment by Larger Bench Not Grounds for Review

DCIT Vs ANI Integrated Services Ltd. (ITAT Mumbai)

The case revolves around the principle established by the Supreme Court regarding the scope of rectification under Section 254(2) of the Income Tax Act. It highlights instances where tribunals have recalled their orders citing non-consideration of prior judgments of jurisdictional high courts or the Supreme Court.

The crux of the matter lies in whether a subsequent judgment can serve as grounds for recalling a finalized tribunal order. The Supreme Court’s stance, as elucidated in various judgments including the pivotal

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