2023 (1) TMI 1407

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..... n is regarding non-discussion of additional ground taken by the assessee - HELD THAT:- There is a delay of 319 days in filing both these miscellaneous applications and as per the amendment to section 254(2) in respect of mistakes to be rectified by the Tribunal the limitation period is up to six months only and the Tribunal does not have power to entertain the miscellaneous application filed beyon .....

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..... l. 4. We have heard both the parties and perused all the relevant material available on record. There is a delay of 319 days in filing both these miscellaneous applications and as per the amendment to section 254(2) in respect of mistakes to be rectified by the Tribunal the limitation period is up to six months only and the Tribunal does not have power to entertain the miscellaneous application f .....

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