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2023 (7) TMI 1405 - ITAT PUNERectification u/s 254 - Deduction u/s 80IB denied for non-filing of a valid sec.139(1) return - HELD THAT:- We are of the view that till the time the assessee fails to pinpoint any apparent mistake in our order within the four corners of sec 254(2) jurisdiction as per Saurashtra Kutch Stock Exchange Ltd. [2008 (9) TMI 11 - SUPREME COURT], Reliance Telecom Ltd. [2021 (12) TMI 211 - SUPREME COURT] and Ramesh Electric and Trading Co. [1992 (11) TMI 32 - BOMBAY HIGH COURT] that our rectification jurisdiction is confined only to correct apparent mistakes than adopting long drawn process of roving enquiries, such a prayer raised at assessee’s behest hardly deserves acceptance. This is indeed coupled with the fact not only we had passed our order [2020 (5) TMI 718 - ITAT PUNE] which was never placed before their lordships but also Order 47 Rule 1 and 2 CPC giving rise to applicability of the Code of Civil Procedure does not apply to Income Tax Act, 1961. We accordingly reject the assessee’s arguments.
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