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TMI Blog2024 (12) TMI 243X X X X Extracts X X X X X X X X Extracts X X X X ..... /s 254(2) of the Act does not lie against the order already passed u/s 254(2) of the Act. It is only an order passed u/s 254(1) of the Act which can be subject matter of rectification u/s 254(2) of the Act. This view is supportable the plain language of the Act as well as various judicial precedents including the Pr. CIT vs Smt. Alpana Bhartia [ 2019 (4) TMI 1035 - KARNATAKA HIGH COURT] and other ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d rival submissions and perused the M.A. filed on behalf of the Revenue. As transpired in the course of hearing, the Revenue has moved the present M.A seeking rectification of the order previously passed by ITAT u/s 254(2) of the Act in M.A. No.535/Del/2018. Apparently, this is ot permissible. The M.A. u/s 254(2) of the Act does not lie against the order already passed u/s 254(2) of the Act. It is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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