Rectification under section 154 cannot determine disputed taxability or exemption claims requiring full assessment review.

Rectification under section 154 cannot be used to decide disputed questions on taxability, exemption, or compliance with the proviso to section 143(3). The assessee's objections required examination of the underlying assessment, the nature of the receipts, and the applicability of sections 11(2) and 11(3), which went beyond correction of an apparent mistake. The authority therefore held that the challenge to accumulated income and the exemption claim was not maintainable in rectification proceedings, and the assessee failed on those grounds.

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Issues: Whether the assessee's challenge to the taxability of accumulated income, the claim of exemption, and the objection based on the proviso to section 143(3) could be adjudicated in proceedings under section 154.

Analysis: The dispute before the authority arose from an order under section 154 reducing the addition after the assessee furnished a year-wise break-up of accumulated income. The remaining controversy was whether the accumulated income was taxable at all, whether it could be said to have been accumulated under section 11, whether the claim of exemption under section 10(23C)(iv) survived, and whether the proviso to section 143(3) was violated. These questions required examination of the underlying assessment, the nature of the receipts, the applicability of sections 11(2) and 11(3), and the larger claim of exemption. Such matters went beyond the narrow ambit of rectification proceedings, which are confined to correcting only apparent mistakes.

Conclusion: The challenge was not maintainable in proceedings under section 154, and the assessee did not succeed on these grounds.

Final Conclusion: The appeal failed because the issues raised involved substantive adjudication outside the limited scope of rectification.

Ratio Decidendi: A proceeding under section 154 cannot be used to decide contested questions requiring examination of the merits of the assessment or the taxability of income, as only apparent mistakes are rectifiable.

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