Rectification under section 154 cannot support a fresh exemption claim or factual enquiry based on a later Supreme Court ruling.

Rectification under section 154 is limited to a patent mistake apparent from the existing record and cannot be used to conduct fresh enquiries, gather foundational facts, reopen the return, or introduce a new claim based on a later Supreme Court ruling. Where the return and computation do not establish that the interest was received under section 28 of the Land Acquisition Act, the necessary facts for applying exemption or substituting the character of the receipt are absent. The request for exemption under section 10(37) and corresponding TDS credit therefore required an examination beyond rectification and amounted to a fresh substantive claim, which was impermissible.

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Issues: Whether rectification under section 154 could be invoked on the basis of a subsequent Supreme Court ruling to substitute the interest disclosed in the return, treat the entire amount as part of enhanced compensation, and grant exemption and corresponding TDS credit.

Analysis: Rectification under section 154 is confined to a mistake apparent from the record. The mistake must be patent, self-evident and ascertainable from the existing record, and the provision cannot be used to conduct an enquiry, collect foundational facts, reopen the return, or make a fresh claim. The assessee had not shown in the return or accompanying computation that the interest was received under section 28 of the Land Acquisition Act, nor did the record establish the foundational facts necessary to apply the subsequent Supreme Court ruling in the rectification proceedings. The claim of exemption under section 10(37) would also require examination of statutory conditions, which could not be undertaken under section 154.

Conclusion: Rectification was not permissible. The request amounted to a fresh claim and a review of the earlier position, which falls outside section 154.

Ratio Decidendi: Section 154 can be invoked only to correct a clear and obvious mistake already apparent from the existing record, and it cannot be used to investigate new facts or to make a fresh substantive claim based on a later judgment.

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