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TMI Blog2021 (7) TMI 529X X X X Extracts X X X X X X X X Extracts X X X X ..... ption under section 54F by following decision of Hon ble Karnataka High Court in case of Anand Basappa [ 2008 (10) TMI 99 - KARNATAKA HIGH COURT] Hon ble Karnataka High Court in case of CIT vs McDowell and Co Ltd [ 2008 (3) TMI 301 - KARNATAKA HIGH COURT] following the decision of Honda Siel Power Products Ltd [ 2007 (11) TMI 8 - SUPREME COURT] has held that the power under section 254 (2) o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of law to the facts of the case in the present pet miscellaneous petition under section 254(2) this Tribunal would be exercising power of review of its earlier order on merits but not rectification of mistake apparent from record and such review would certainly is beyond the scope of section 254(2). - MP No.17/Bang/2021 (in ITA 2818/Bang/2018) - - - Dated:- 22-6-2021 - Shri. Chandra Poojari, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eous petition could not be filed within the period of limitation. 3. We have perused the submissions advanced by the Ld. DR in support of can donation of delay. Hon ble Supreme Court by order dated 23/3/2020 extended the period of limitation that expired during the lockdown period of Covid 19 pandemic w.e.f 15/3/2020. 4. Admittedly the limitation period to file the present miscellaneous peti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sions advanced by both sides in light of records placed before us. 9. We note that this tribunal denied the exemption under section 54F by following decision of Hon ble Karnataka High Court in case of Anand Basappa reported in 309 ITR 329. 10. The Hon ble Karnataka High Court in case of CIT vs McDowell and Co Ltd. reported in (2009) 310 ITR 215 following the decision of Hon ble Supreme Court ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the application of principles laid down by Hon ble Supreme Court to the facts of the case or by reconsidering its findings recorded or by reconsidering the application of the relevant provisions of law to the facts of the case in the present pet miscellaneous petition under section 254(2) this Tribunal would be exercising power of review of its earlier order on merits but not rectification of mis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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