Debatable tax deduction issues cannot be withdrawn through rectification when no patent mistake appears on the record.

Withdrawal of deduction under section 80-I through rectification under section 154 was impermissible because a mistake apparent from the record must be obvious and patent, not one requiring detailed reasoning or open to two views. Where entitlement to the deduction is itself debatable, the matter cannot be reopened by rectification. The rectification order was therefore unsustainable since the alleged error did not amount to a mistake apparent from the record.

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Issues: Whether relief granted under section 80-I of the Income-tax Act, 1961 could be withdrawn by invoking section 154 of the Income-tax Act, 1961 on the ground that the earlier grant of deduction was a mistake apparent from the record.

Analysis: A mistake apparent from the record must be an obvious and patent error and not one that requires a long drawn process of reasoning or admits of two possible views. Where entitlement to deduction under section 80-I is itself debatable, withdrawal of the relief cannot be effected through rectification under section 154.

Conclusion: The rectification order was unsustainable because the issue was debatable and did not constitute a mistake apparent from the record.

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