Commissioner of Income Tax v. Reliance Telecom Ltd.

Income Tax Act, 1961 – Section 254 (2) – the powers under Section 254(2) of the Act are only to correct and/or rectify the mistake apparent from the record and not beyond that.

The powers under Section 254(2) of the Act are akin to Order XLVII Rule 1 CPC. While considering the application under Section 254(2) of the Act, the Appellate Tribunal is not required to re-visit its earlier order and to go into detail on merits. The powers under Section 254(2) of the Act are only to rectify/correct any mistake apparent from the record.