#ITAT jurisdiction

The ITAT Delhi has firmly held that Section 254(2) of the Income Tax Act permits correction of clerical or obvious mistakes only, and cannot be used to re-evaluate factual or legal merits already decided. This reinforces the finality of tribunal orders and prevents parties from using rectification as a backdoor appeal, directly impacting tax litigants and revenue authorities seeking to reopen concluded cases.

The ITAT Jodhpur has dismissed a revenue appeal under Assessment Year 2018-19 because the tax effect of ₹12.90 lakh fell below the ₹60 lakh minimum mandated by CBDT Circular No. 09/24, reinforcing that procedural thresholds override substantive disputes. This sets a clear precedent for departments to prioritize appeals only where financial stakes meet the prescribed limit, curbing frivolous litigation across income tax adjudication.

ITAT Delhi dismisses appeal for lack of territorial jurisdiction, holding that the situs of the Assessing Officer-not the assessee’s location-determines the appropriate bench. The ruling reinforces the binding precedent from the Supreme Court in PCIT Vs. ABC Papers Ltd., impacting taxpayers filing appeals under the Income Tax Act.