ITAT Cannot Re-Adjudicate Issues Under Guise Of Rectification U/S 254(2) Income Tax Act: Madras High Court

The Madras High Court clarified that the rectification power under Section 254(2) of the Income Tax Act is strictly limited to correcting mistakes that are apparent on the face of the record. It ruled that the Income Tax Appellate Tribunal cannot use this provision as a backdoor to re-adjudicate or revisit the merits of a case. The Court compared this power with the scope of review under Order 47 Rule 1 of the Civil Procedure Code, stressing that substantive errors must be challenged through proper appellate remedies. The judgment safeguards the finality of tribunal orders, prevents misuse of procedural provisions, and promotes legal certainty and procedural discipline in tax litigation.