The Tax Publishers2021 TaxPub(DT) 0779 (Pune-Trib)

INCOME TAX ACT, 1961

Section 254(2)

Miscellaneous application filed by the revenue was dismissed on all counts on the ground of failure of AO to record satisfaction as to which limb of section 271 (1)(c) had not been complied with by the assessee.

Appeal (Tribunal) - Rectification under section 254 - No perversity in order of Tribunal -

Revenue sought rectification of order of Tribunal on the ground that Tribunal had allowed the appeal of assessee on technical ground and deleted the penalty levied under section 271(1)(c). Held: No mistake apparent from record within the purview of section 254(2) and hence, miscellaneous application filed by the revenue was dismissed on all counts on the ground of failure of AO to record satisfaction as to which limb of section 271(1)(c) had not been complied with by assessee.

REFERRED :

FAVOUR : In favour of assessee.

A.Y. : 2011-12



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