PANCHSHEEL SOLVENT PVT. LTD., RAJANANDGOAN,RAJANANDGOAN V. ACIT, CENTRAL-2, RAIPUR, RAIPUR

MA 17/RPR/2025

AI Insights

The case involves Panchsheel Solvent P. Ltd., which filed a miscellaneous application seeking to recall an order passed by the Income Tax Appellate Tribunal (ITAT) in IT(SS)A No. 5/RPR/2024. The original order dismissed the assessee's appeal due to non-prosecution. The assessee argued that there was a mistake apparent from the record and cited changes in counsel and lack of opportunity to present necessary documents. The Tribunal, however, found that the assessee was given ample opportunity to present its case and that the issues raised did not constitute a mistake apparent from the record. The Tribunal referenced several precedents to affirm that its powers under Section 254(2) do not allow for a review or re-hearing of the case on merits.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 711632 (ITAT-RAIPUR)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 24-07-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Assessment Year: 2013-2014
• Other Referred Cases: Hitesh Golecha vs. ACIT, Central Circle-1, Raipur, Commissioner of Income Tax (IT-4), Mumbai v. Reliance Telecom Limited, CIT vs. HERO CYCLES (P) LTD, ACIT vs. SAURASHTRA KUTCH STOCK EXCHANGE LTD, CIT vs. Karam Chand Thapar & Bros. (P.) Ltd.
• Laws Referred To: Income Tax Act
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: PRIYANKA PATEL
• Assessee Lawyers: SUNIL KUMAR AGRAWAL
• Keywords: Set aside; Reasonable cause; Principle of natural justice; Rectification of order
• Section: 143(3); 154; 153A

Judgement Text

"आयकर अपीलीय अिधकरण, रायपुर Ɋायपीठ, रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR Įी पाथ[ सारथी चौधरȣ, Ɋाियक सद˟ एवं ŵी अŜण खोड़िपया, लेखा सद˟ क े समƗ । BEFORE SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI ARUN KHODPIA, AM आयकर अपील सं. / MA No: 17/RPR/2025 (Arising out of IT(SS)A No. 5/RPR/2024) (िनधाŊरण वषŊ Assessment Year: 2013-14) M/s Panchsheel Solvent P. Ltd., Bakal Road, Vill-Indamara, Rajnandgaon, 491441, (C.G.). v s Assistant Commissioner of Income Tax, Central-2, Raipur (C.G.). PAN: AAECP8898A (अपीलाथŎ/Appellant) . . (ŮȑथŎ / Respondent) िनधाŊįरती की ओर से / Assessee by : Shri Sunil Kumar Agrawal, CA राजˢ की ओर से / Revenue by : Dr. Priyanka Patel, Sr. DR सुनवाई की तारीख / Date of Hearing : 18.07.2025 घोषणा की तारीख / Date of Pronouncement : 24.07.2025 आदेश / O R D E R Per Arun Khodpia, AM: The captioned miscellaneous application is filed by the assessee seeking re-calling of the impugned order passed by the Tribunal in IT(SS)A No. 5/RPR/2024, dated 26.12.2024. 2. The contents of the MA raising grievance submitted by the assessee are extracted as under, for the sake of completeness: Printed from counselvise.com 2 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax Printed from counselvise.com 3 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax 3. While challenging the impugned order of the Tribunal to point out a mistake apparent from record as stipulated under the provisions of Section 254(2), it was the submission by the Ld. AR representing the assessee that the order of Ld. CIT(A) under consideration before the Bench was an ex-parte order under section 250 of the Act passed on 02.02.2024, wherein the appeal of assessee was dismissed on account of non-prosecution, however, the Tribunal has decided the case and dismissed the appeal of the assessee which constitutes a mistake on the part of the ITAT. 4. The second contention raised by the Ld. AR was that there is a change of counsel during the course of hearing before the ITAT. However, the new Printed from counselvise.com 4 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax counsel was not provided with reasonable time for filing of factual paper book along with necessary documents and preparation of the case, again has been a mistake apparent on the record. 5. It was the submission by the Ld. AR that in absence of proper opportunity given to the assessee, it is a violation of principles of natural justice in absence of any papers / documents / paper book before the Bench, accordingly, the matter deserves to be re-called. 6. Per contra, Ld. Sr. DR, Dr. Priyanka Patel vehemently relied upon the order of the ITAT and have submitted that the ITAT has discussed all the issues and contentions raised by the assessee in the appeal before it and have deliberated at length in their 81 pages order, therefore, it cannot be said that the matter was decided on an ex-parte basis as on the date of hearing the counsel, namely, Shri Sunil Kumar Agrawal and Shri Vimal Kumar Agrawal, CAs both were very much present in the proceedings when the matter was heard at length. 7. Further, Ld. AR drew our attention to the issue challenging the validity of the assessment order passed u/s 153A read with section 143(3) of the Act and approval u/s 153D stating that the order of assessment and approval was granted by way of consolidated and combined/common approval which is not Printed from counselvise.com 5 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax in accordance with the mandate of law described under the impugned section of Act on which the ITAT had written a incorrect statement and misapplied the decision of the Hon’ble jurisdictional High Court in the case of Hitesh Golecha vs. ACIT, Central Circle-1, Raipur in TAXC No.76/2024, dated 10.04.2024 and have discussed the issue at length and finally dismissed the aforesaid contentions of the assessee. Before us in the present MA, it was the contention raised by the Ld. AR that the reliance on the judgment of Hitesh Golecha (supra) was not properly interpreted by the ITAT and therefore, again the matter comes within the purview of mistake apparent on record within the provision of section 254 (2) of the Act. 8. We have considered the rival submission, material available on record and the case law relied upon by the parties. 9. Admittedly, the assessee’s appeal was decided in the presence of counsel of assessee i.e. Shri Sunil Kumar Agrawal and Shri Vimal Kumar Agrawal, CAs, however, the allegation made by the assessee that no proper opportunities was granted with the assessee cannot be acceded to for the reason that the appeal of the assessee was decided after long hearings on 28.05.2024, 05.06.2024, 27.08.2024, 28.08.2024, 02.09.2024, 04.09.2024 and 23.09.2024 and final hearing was conducted on 22.10.2024. It is further emanating from the record that on the aforesaid occasions the hearing was Printed from counselvise.com 6 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax attended by the counsel of the assessee or by the assessee himself in person, therefore, it cannot be said that the assessee was not provided with sufficient opportunities to represent its case. Therefore, the contention raised by the AR cannot be concurred with. 10. Since, the appeal of the assessee has been decided by the Tribunal after proper appreciation of the facts, following the judicial precedents and interpreted the same which might be against the assessee, therefore, it cannot be said that there is some mistake apparent from record within the meaning of provision 254(2) of the Act and accordingly, on account of which the case of the assessee merits to be re-called. 11. Herein, we observe that the counsel of the assessee under his own conviction is of the view that there is a mistake apparent on the record and is trying to get the order re-called which is nothing but to requesting the review the order of the Tribunal by tribunal itself, which is not permissible under the scope of provision of section 254(2) of the Act. 12. Considering the aforesaid observations, facts and circumstances, we, are of the considered opinion that in the present case there is no mistake apparent from record, the tribunal is functus officio about the decision already accorded, therefore, the MA filed by the assessee with the request to recall the Printed from counselvise.com 7 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax matter is leading towards the review of the appeal, which is not permissible as per the mandate of law, accordingly, the MA of assessee is not sustainable. 13. To support the aforesaid observations, that the tribunal is not empowered to reconsider / revisit its own order under the provisions of section 254(2) as held by various Hon’ble Courts. The mandate of law which allows the tribunal to deal with miscellaneous application, the tribunal has limited powers to rectify any apparent and glaring mistake on the face of records. The tribunal is not expected to re-hear the entire case on merits or to revisit its earlier order and to deal with the merits on the basis of lengthy deliberations and arguments by the appellant. 14. In this respect, the principle of law laid down by Hon’ble Apex Court in the case of Commissioner of Income Tax (IT-4), Mumbai v. Reliance Telecom Limited dated December 3, 2021, in Civil Appeal No. 7110 of 2021 reported in [2021] 133 taxmann.com 41 (SC), shall be relevant and binding on us to follow, wherein Hon’ble Apex Court has held as under: 3.2 Having gone through both the orders passed by the ITAT, we are of the opinion that the order passed by the ITAT dated 18-11-2016 recalling its earlier order dated 6-9-2013 is beyond the scope and ambit of the powers under section 254(2) of the Act. While allowing the application under section 254(2) of the Act and recalling its earlier order dated 6-9-2013, it appears that the ITAT has re-heard the entire appeal on merits as if the ITAT was deciding the appeal against the order passed by the C.I.T. In exercise of powers under section 254(2) of the Act, the Appellate Tribunal may amend any order passed by it under sub-section (1) of section 254 of the Act with a view to rectifying any mistake apparent from the record only. Therefore, the powers Printed from counselvise.com 8 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax 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. 4. In the present case, a detailed order was passed by the ITAT when it passed an order on 6-9- 2013, by which the ITAT held in favour of the Revenue. Therefore, the said order could not have been recalled by the Appellate Tribunal in exercise of powers under section 254(2) of the Act. If the Assessee was of the opinion that the order passed by the ITAT was erroneous, either on facts or in law, in that case, the only remedy available to the Assessee was to prefer the appeal before the High Court, which as such was already filed by the Assessee before the High Court, which the Assessee withdrew after the order passed by the ITAT dated 18-11-2016 recalling its earlier order dated 6-9-2013. Therefore, as such, the order passed by the ITAT recalling its earlier order dated 6-9-2013 which has been passed in exercise of powers under section 254(2) of the Act is beyond the scope and ambit of the powers of the Appellate Tribunal conferred under section 254(2) of the Act. Therefore, the order passed by the ITAT dated 18-11-2016 recalling its earlier order dated 6-9-2013 is unsustainable, which ought to have been set aside by the High Court. 5. From the impugned judgment and order passed by the High Court, it appears that the High Court has dismissed the writ petitions by observing that (i) the Revenue itself had in detail gone into merits of the case before the ITAT and the parties filed detailed submissions based on which the ITAT passed its order recalling its earlier order; (ii) the Revenue had not contended that the ITAT had become functus officio after delivering its original order and that if it had to relook/revisit the order, it must be for limited purpose as permitted by section 254(2) of the Act; and (iii) that the merits might have been decided erroneously but ITAT had the jurisdiction and within its powers it may pass an erroneous order and that such objections had not been raised before ITAT. 6. None of the aforesaid grounds are tenable in law. Merely because the Revenue might have in detail gone into the merits of the case before the ITAT and merely because the parties might have filed detailed submissions, it does not confer jurisdiction upon the ITAT to pass the order de hors section 254(2) of the Act. As observed hereinabove, 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. Even the observations that the merits might have been decided erroneously and the ITAT had jurisdiction and within its powers it may pass an order recalling its earlier order which is an erroneous order, cannot be accepted. As observed hereinabove, if the order passed by the ITAT was erroneous on merits, in that case, the remedy available to the Assessee was to prefer an appeal before the High Court, which in fact was filed by the Assessee before the High Court, but later on the Assessee withdrew the same in the instant case. Printed from counselvise.com 9 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax 15. We may herein also note that in the case of CIT v. Pearl Woolen Mills [2011] 330 ITR 164/[2010] 191 Taxman 286 (Punj. &Har.), Hon’ble Punjab & Haryana High Court have accorded similar findings which reads as under: “Held, that the Tribunal could not re adjudicate the matter under section 254(2). It is well settled that a statutory authority cannot exercise power of review unless such power is expressly conferred. There was no express power of review conferred on the Tribunal. Even otherwise, the scope of review did not extent to rehearing a case on the merits. Neither by invoking inherent power nor the principle of mistake of court not prejudicing a litigant nor by involving doctrine of incidental power, could the Tribunal reverse a decision on the merits. The Tribunal was not justified in recalling its previous finding restoring the addition, more so when an application for the same relief had been earlier dismissed.\" 16. In the case of CIT v. Hindustan Coca Cola Beverages (P.) Ltd. [2007] 293 ITR 163/159 Taxman 122 (Delhi), their Lordships while considering the powers of the Tribunal under s. 254(2) of the IT Act, 1961 observed as under: “Under s. 254(2) of the IT Act, 1961, the Tribunal has the power to rectify mistakes in its order. However, it is plain that the power to rectify a mistake is not equivalent to a power to review or recall the order sought to be rectified. Rectification is a species of the larger concept of review. Although it is possible that the pre-requisite for exercise of either power may be similar (a mistake apparent from the record), by its very nature the power to rectify a mistake cannot result in the recall and review of the order sought to be rectified.” 17. Regarding scope of application of section 254(2), coordinate bench of the tribunal, ITAT Hyderabad, A bench in the case of Sri Madireddy Venkat Reddy v. Additional Commissioner of Income-tax, Range -11, Hyderabad reported in [2013] 38 taxmann.com 60 (Hyderabad - Trib.) has dealt in detail and has observed as under: Printed from counselvise.com 10 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax 9. The scope and ambit of application of section 254(2) is very limited. The same is restricted to rectification of mistakes apparent from the record. We shall first deal with the question of the power of the Tribunal to recall an order in its entirety. Recalling the entire order obviously would mean passing of a fresh order. That does not appear to be the legislative intent. The order passed by the Tribunal under s. 254(1) is the effective order so far as the appeal is concerned. Any order passed under s. 254(2) either allowing the amendment or refusing to amend gets merged with the original order passed. The order as amended or remaining unamended is the effective order for all practical purposes. An order under s. 254(2) does not have existence de hors the order under s. 254(1). Recalling of the order is not permissible under s. 254(2). Recalling of an order automatically necessitates rehearing and re- adjudication of the entire subject matter of appeal. The dispute no longer remains restricted to any mistake sought to be rectified. Power to recall an order is prescribed in terms of Rule 24 of the ITAT Rules, 1963, and that too only in case where the assessee shows that it had a reasonable cause for being absent at a time when the appeal was taken up and was decided ex parte. Judged in the above background the order passed by the Tribunal is indefensible. 10. The words used in s. 254(2) are 'shall make such amendment, if the mistake is brought to its notice'. Clearly, if there is a mistake, then an amendment is required to be carried out in the original order to correct that particular mistake. The provision does not indicate that the Tribunal can recall the entire order and pass a fresh decision. That would amount to a review of the entire order and that is not permissible under the IT Act. The power to rectify a mistake under s. 254(2) cannot be used for recalling the entire order. No power of review has been given to the Tribunal under the IT Act. Thus, what it could not do directly could not be allowed to be done indirectly. 11. In the case of CIT v. Hindustan Coca Cola Beverages (P.) Ltd. [2007] 293 ITR 163/159 Taxman 122 (Delhi), their Lordships while considering the powers of the Tribunal under s. 254(2) of the IT Act, 1961 observed as under: \"Under s. 254(2) of the IT Act, 1961, the Tribunal has the power to rectify mistakes in its order. However, it is plain that the power to rectify a mistake is not equivalent to a power to review or recall the order sought to be rectified. Rectification is a species of the larger concept of review. Although it is possible that the pre-requisite for exercise of either power may be similar (a mistake apparent from the record), by its very nature the power to rectify a mistake cannot result in the recall and review of the order sought to be rectified.\" 12. Thus the scope and ambit of application u/s. 254(2) is as follows: Printed from counselvise.com 11 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax \"(a) Firstly, the scope and ambit of application of s. 254(2) of IT Act is restricted to rectification of the mistakes apparent from the record. (b) Secondly, that no party appearing before the Tribunal should suffer on account of any mistake committed by the Tribunal and if the prejudice has resulted to the party, which prejudice is attributable to the Tribunal's mistake/error or omission, and which an error is a manifest error, then the Tribunal would be justified in rectifying its mistake. The \"rule of precedent\" is an important aspect of legal certainty in the rule of law and that principle is not obliterated by s. 254(2) of the Act and non-consideration of precedent by the Tribunal causes a prejudice to the assessee. (c) Thirdly, power to rectify a mistake is not equivalent to a power to review or recall the order sought to be rectified. (d) Fourthly, under s. 254(2) an oversight of a fact cannot constitute an apparent mistake rectifiable under the section. (e) Fifthly, failure on the part of the Tribunal to consider an argument advanced by either party for arriving at a conclusion is not an error apparent on record, although it may be an error of judgment. (f) Sixthly, even if on the basis of a wrong conclusion the Tribunal has not allowed a claim of the party it will not be a ground for moving an application under s. 254(2) of the Act. (g) Lastly, in the garb of an application for rectification under s. 254(2) the assessee cannot be permitted to reopen and reargue the whole matter as the same is beyond the scope of s. 254(2) of the IT Act.\" 13. Further, the order of the Tribunal is to be read in a whole and not in a piecemeal manner. For this purpose, we place reliance on the judgment of Supreme Court in the case of CIT v. Karam Chand Thapar & Bros. (P.) Ltd. [1989] 176 ITR 535/43 Taxman 45 wherein held that the decision of the Tribunal has not to be scrutinised sentence by sentence merely to find out whether all facts USP have been set out in detail by the Tribunal or whether some incidental fact which appears on the record has not been noticed by the Tribunal in its judgment. If the court, on a fair reading of the judgment of the Tribunal, finds that it has taken into account all relevant material and has not taken into account any irrelevant material in basing its conclusions, the decision of the Tribunal is not liable to be interfered with, unless, of course, the conclusions arrived at by the Tribunal are perverse. It is not necessary for the Tribunal to state in its judgment specifically or in express words that it has taken into account the cumulative effect of the circumstances or has considered the totality of the facts, as if that were a magic formula; if the judgment of the Tribunal shows that it has, in fact, done so, there is no reason to interfere with the decision of the Tribunal. Printed from counselvise.com 12 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax 14. In view of the above discussion, we find no merit in the argument of the assessee's counsel. The Tribunal cannot review its own order and the remedy lies elsewhere. We do not find any mistake apparent on record which warrants rectification of Tribunal's order. 15. In the result, the MA filed by assessees is dismissed. 18. Regarding a mistake apparent from record there are landmark judgments wherein it has been explicitly explained and ruled that what should be categorized as a mistake apparent on record. For the sake of clarity, the three relevant judgments by Hon’ble Apex Court are extracted as under: I. T.S. Balaram, ITO v. Volkart Brothers*[1971] 82 ITR 50 (SC) DB \"A mistake apparent on the record must be an obvious and patent mistake and not something which can be established by a long-drawn process of reasoning on points on which there may conceivably be two opinions. As seen earlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale [I960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long-drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of law is not a mistake apparent from the record—see Sidhramappa Andannappa Manvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income-tax Act, 1961, to correct “any mistake apparent from the record” is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an “error apparent on the face of the record.” In this case it is not necessary for us to spell out the distinction between the expressions “error apparent on the face of the record” and “mistake apparent from the record”. But suffice it to say that the Income-tax Printed from counselvise.com 13 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax Officer was wholly wrong in holding that there was a mistake apparent from the record of the assessments of the first respondent.’’ II. CIT vs. HERO CYCLES (P) LTD etc. (1997)228 ITR 463(SC) Civil Appeal No.7665/96 2. The High Court declined to call for a reference under s. 256(2) of the IT Act, 1961. It appears that the claim for deduction under s. 35B was not originally allowed at all. Thereafter, on an assessee’s application an order was passed by the CIT(A), Jalandhar, in which he directed certain allowances to be given on proportionate basis after verification of the assessee’s claim under s. 35B. The ITO thereafter entertained assessee’s prayer for rectification of the order and allowed the assessee’s claim in respect of matters like coloured albums, export staff travelling expenses, export sales commission, ECGC, foreign dealers visiting expenses. Rectification under s. 154 can only be made when glaring mistake of fact or law has been committed by the officer passing the order becomes apparent from the record. Rectification is not possible if the question is debatable. Moreover, the point which was not examined on fact or in law cannot be dealt as mistake apparent on the record. The dispute raised a mixed question of fact and law. The Tribunal was in error in upholding the assessee’s claim for weighted deductions. There is no point in sending the matter to the High Court to deal with the question raised at this stage. We treat the question as referred to this Court and answer the question in the negative and in favour of the Revenue. There will be no order as to costs. The appeal is allowed. III. ACIT v. SAURASHTRA KUTCH STOCK EXCHANGE LTD. [2008] 305 ITR 227 (SC) DB 37. In our judgment, therefore, a patent, manifest and self-evident error which does not require elaborate discussion of evidence or argument to establish it, can be said Printed from counselvise.com 14 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax to be an error apparent on the face of the record and can be corrected while exercising certiorari jurisdiction. An error cannot be said to be apparent on the face of the record if one has to travel beyond the record to see whether the judgment is correct or not. An error apparent on the face of the record means an error which strikes on mere looking and does not need a long-drawn-out process of reasoning on points where there may conceivably be two opinions. Such error should not require any extraneous matter to show its incorrectness. To put it differently, it should be so manifest and clear that no court would permit it to remain on record. If the view accepted by the court in the original judgment is one of possible views, the case cannot be said to be covered by an error apparent on the face of the record. 19. In view of the aforesaid binding, guiding and settled principle of law respectfully following the same, we reject the MA filed by the assessee, requesting for review of the earlier order of the tribunal in the garb of rectification of mistake by way of long drawn process of reasonings and arguments which is neither permissible nor allowed as per mandate of law. 20. It would be pertinent to note that, in the instant case, the Ld. AR of the assessee is unable to point out any mistake apparent / obvious emanating from the records which demands for rectification which is permissible within the scope of provisions of section 254(2), thus, in absence of any mistake apparent on record which warrants rectification in the impugned order of the tribunal, the contentions / dispute raised by the assessee in present MA found to be devoid and bereft of any merit / substance, thus, cannot be acceded to. Printed from counselvise.com 15 MA No. 17/RPR/2025 Arising out of IT(SS)A No. 5/RPR/2024 Panchsheel Solvent vs. Assistant Commissioner of Income Tax 21. In result, the MA of the assessee in MA No. 17/RPR/2025 stands dismissed in terms of our aforesaid observations. Order pronounced in the open court on 24/07/2025. Sd/- (PARTHA SARATHI CHAUDHURY) Sd/- (ARUN KHODPIA) Ɋाियक सद˟ / JUDICIAL MEMBER लेखा सद˟ / ACCOUNTANT MEMBER रायपुर / Raipur; िदनांक Dated 24/07/2025 Vaibhav Shrivastav आदेशकी Ůितिलिप अŤेिषत / Copy of the Order forwarded to : आदेशानुसार/ BY ORDER, (Senior Private Secretary) आयकर अपीलीय अिधकरण, रायपुर / ITAT, Raipur 1. अपीलाथŎ/ The Appellant- Panchseel Solvant P. Ltd 2. ŮȑथŎ/ The Respondent- ACIT, Circle-2,Raipur 3. The Pr. CIT, Raipur (C.G.) 4. िवभागीय Ůितिनिध, आयकर अपीलीय अिधकरण, रायपुर/ DR, ITAT, Raipur 5. गाडŊ फाईल / Guard file. // सȑािपत Ůित True copy // Printed from counselvise.com "