Scope of Section 254(2) Limited to Apparent Mistakes, No Review Permitted: ITAT Surat

ITO Vs Smt. Laxmiben Amratlal Patel (ITAT Surat)

In the case of ITO vs. Smt. Laxmiben Amratlal Patel (ITAT Surat), the Income Tax Department filed a Miscellaneous Application (MA) under Section 254(2), seeking rectification or recall of an earlier tribunal order dated 27.03.2024 for the Assessment Year 2012-13. The department argued that the tribunal had overlooked key facts, specifically regarding the sale of non-agricultural land. It contended that the assessee had sold land valued at ₹2.09 crore but did not declare capital gains, claiming the land was agricultural and exempt.

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