Rectification aligned with earlier appellate findings on capital gains deductions, so the department's challenge failed.

Rectification of the appellate order allowing deductions under sections 54EC and 54 was upheld because it merely aligned the order with the factual position already accepted in earlier appellate proceedings. The record showed no further modification to the direction granted by the Commissioner (Appeals), so no interference was warranted. The department's challenge therefore failed, and the rectification order remained in force.

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Issues: Whether the rectification order allowing deductions aggregating to Rs. 49.98 lakhs under sections 54EC and 54 of the Income-tax Act, 1961 called for interference.

Analysis: The rectification merely aligned the order with the factual position already considered and sustained in the earlier appellate proceedings. No further modification in the direction granted by the Commissioner (Appeals) was shown to exist.

Conclusion: The rectification order was upheld and the department's challenge failed.

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