Rectification application of assessee not to entertained in case assessee’s conduct was speculative

PCIT Vs N. R. Portfolio (Delhi High Court) Conclusion: The conduct of the assessee was speculative, it was not an uninformed litigant; it calculatedly chose not to question the rejection of its cross objection. Instead, waited more than a year after the decision of this court (which was rendered on 21-12-2012) till the two members who decided the first ITAT orders were not available and choosing to prefer the rectification application at a convenient time, assessee no doubt technically was compliant, but stood exposed to the odium of forum shopping. Thus, ITAT order reversed with costs of Rs. ...