Rectification under section 154 is unavailable for debatable issues or mistakes not apparent from the record.

Rectification under section 154 of the Income-tax Act, 1961 is limited to obvious and patent mistakes apparent from the record. Where identifying the alleged error requires a long-drawn process of reasoning or the issue admits of more than one plausible view, the matter becomes debatable and falls outside rectification jurisdiction. On that basis, the alleged mistake was not apparent from the record and the rectification order could not be sustained; the referred question was answered in favour of the assessee.

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Issues: Whether a rectification order could be sustained under section 154 of the Income-tax Act, 1961 when the alleged mistake was not patent and the controversy admitted of more than one possible view.

Analysis: Rectification under section 154 is confined to obvious and patent mistakes apparent from the record. Where the issue requires a long-drawn process of reasoning and two conceivable views are possible, the matter becomes debatable and falls outside the scope of rectification jurisdiction.

Conclusion: The alleged mistake was not apparent from the record, and the rectification under section 154 could not be sustained. The answer to the referred question is in the affirmative, in favour of the assessee.

Ratio Decidendi: A mistake that is debatable or capable of two plausible views is not a mistake apparent from the record and cannot be rectified under section 154 of the Income-tax Act, 1961.

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