Subsequent SC Ruling Not Ground for Section 254(2) ITAT Rectification: Bombay HC

Prakash D. Koli Vs Income Tax Appellate Tribunal (Bombay High Court) Bombay High Court in Prakash D. Koli vs. Income Tax Appellate Tribunal examined the validity of the ITAT’s order dated 4 August 2023, passed under Section 254(2) of the Income Tax Act, 1961, and the consequential order dated 26 October 2023. The petitioner challenged these orders on the ground that the Tribunal exceeded its jurisdiction under Section 254(2), which only permits rectification of mistakes apparent on the face of the record. The dispute originated from an assessment in which the Assessing Officer (AO) disallowe...