Rectification addition fails where TDS mismatch is explained by books, remand verification and admitted evidence showing no discrepancy.

A rectification addition under section 154 was held unsustainable where the apparent mismatch with the TDS certificate was explained by the assessee's evidence that the certificate covered both agency commission and detention commission, and the detention commission had already been reflected in the books. Additional evidence was admitted without objection, the remand report verified the certificates, ledger entries and reversal entries, and the Assessing Officer found no discrepancy on verification. The appellate authority therefore treated the original rectification as having been made without the complete material on record, and the deletion of the addition was upheld.

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Issues: Whether the rectification addition made under section 154 on account of the difference between the TDS certificate and the commission income disclosed in the books was sustainable.

Analysis: The assessee demonstrated that the TDS certificate covered both agency commission and detention commission, and that the detention commission had been separately reflected in the profit and loss account. Additional evidence was admitted with no objection from the revenue authorities, and the remand report confirmed the relevant certificates, ledger entries, and reversal entries. On verification, the Assessing Officer found no discrepancy in the books, and the CIT(A) concluded that the original rectification order had been passed without the complete material then on record.

Conclusion: The addition made under section 154 was not sustainable, and the deletion of the addition was .

Final Conclusion: The revenue failed to dislodge the factual findings supporting deletion of the rectification addition, and the appellate order in favour of the assessee was upheld.

Ratio Decidendi: A rectification addition based on an apparent mismatch with a TDS certificate cannot survive where the assessee establishes, through admitted additional evidence and remand verification, that the disputed amount was already accounted for in the books.

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