Rectification under section 154 fails where deduction entitlement turns on a debatable question of law and fact.

Section 154 cannot be used to withdraw relief where the underlying entitlement to deduction under section 80-I depends on a debatable question of law and fact. The controversy over whether the payment to the Cooperative Education Fund qualified for the deduction scheme required examination and reasoning, so it was not an obvious or patent error apparent from the record. A rectification power is limited to clear mistakes and cannot be invoked merely because the revenue later adopts a different view. The rectification order was therefore unjustified and could not stand.

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Issues: Whether the Assessing Officer could invoke section 154 to withdraw relief granted while giving effect to the appellate order, when the entitlement to deduction under section 80-I depended on a debatable question of law and fact.

Analysis: The entitlement to deduction on the amount contributed to the Cooperative Education Fund turned on whether the payment could be treated in the manner asserted by the assessee for purposes of the deduction scheme. That controversy required examination and reasoning, and was not an obvious or patent error. A rectification under section 154 is confined to mistakes apparent from the record and cannot be used where the issue is debatable or where the conclusion depends on a process of reasoning. On the facts, the relief earlier granted could not be characterised as an apparent mistake merely because the revenue later took a different view.

Conclusion: The invocation of section 154 was unjustified and the rectification order could not stand.

Ratio Decidendi: A decision on a debatable point of law or fact is not a mistake apparent from the record and cannot be corrected under section 154.

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