No rectification under section 154 in section 264 Revisional order on new issues

Rakesh Agarwal Vs ITO (Calcutta High Court) The Court:-The petitioner has challenged the impugned order dated 20th December, 2011 rejecting the petitioner’s application under Section 154 of the Income Tax Act, 1961 for rectification of the alleged mistake in the order dated 22nd December, 2011 passed under Section 264 of the Act on the ground that the Commissioner while disposing of the application of the petitioner under Section 264 of the Act has committed a mistake apparent from records by not taking into consideration or dealing with the issues raised by the petitioner in his order under...