Rectification under section 154 requires an error apparent on the record; later returns cannot justify withdrawal of development rebate.

Section 154 allows rectification only of a mistake apparent from the record, so a development rebate already allowed in original assessment could not be withdrawn where the alleged factual basis was not evident from the assessment record for that year. The Court noted that there was no entry in the relevant record showing the machinery had been let out or not used in the assessee's business, and a later return for a subsequent year could not be used to supply the basis for rectification of the earlier assessment. The Income-tax Officer therefore lacked jurisdiction to invoke section 154, and relief was granted to the assessee.

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Issues: Whether the development rebate allowed in the original assessment could be withdrawn by rectification under section 154 of the Income-tax Act, 1961, when the alleged factual basis was not apparent from the assessment record.

Analysis: Section 154 permits rectification only of a mistake apparent from the record. The material before the Court showed no entry in the assessment record for the relevant assessment year indicating that the machinery had been let out and not used for the assessee's business. The later return for a subsequent year could not furnish the basis for rectification of the earlier assessment, because the alleged error was not evident on the existing record for the year under reference.

Conclusion: The Income-tax Officer had no jurisdiction to invoke section 154 to withdraw the development rebate, and the answer was in favour of the assessee.

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