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TMI Blog2019 (7) TMI 353X X X X Extracts X X X X X X X X Extracts X X X X ..... of return by way of suo motu action, is required to be corroborated on the basis of material on record. Since at this stage, in terms of the limited jurisdiction available with us in terms of section 254(2) of the Act, only apparent mistakes can be corrected, we deem it fit and proper to direct the Assessing Officer to verify this aspect of the matter. The assessee is required to satisfy the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... venue seeks to recall the order of the Tribunal dated 13.07.2016 in ITA No. 4827/Mum/2012 for A.Y. 2008-09. 2. The captioned Miscellaneous Application u/s. 254(2) of the Act has been preferred by the Revenue in the context of Ground of appeal nos. 4 to 6 disposed of by the Tribunal relating to disallowance of ₹ 1,05,47,651/-. It is pointed out by the learned DR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed on the factual position and, therefore, there is no wrong. 5. Having heard the rival submissions we find the say of the assessee that the impugned amount of ₹ 1,05,47,651/- has already suffered disallowance at the time of filing of return by way of suo motu action, is required to be corroborated on the basis of material on record. Since at this stage, in terms of the limit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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