Apparent mistake in return processing justified merits-based rectification where the same income may have been taxed twice.

Inconsistency between the original return and the return filed after the defect notice created an apparent mistake in the intimation, because the processing order applied a special tax rate even though the special-rate column showed nil income. The authority was required to examine whether the same income had been taxed twice, and the rectification request could not be rejected without a merits-based consideration, notwithstanding the assessee's negligent filing. The matter was therefore restored to the assessing authority to decide the rectification application on merits after giving the assessee an opportunity of hearing.

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Issues: Whether the intimation processing the return contained an apparent mistake warranting rectification and whether the matter should be restored for decision on merits.

Analysis: The return as filed and the return furnished in response to the defect notice showed inconsistent reporting of the same receipt, and the processing order computed tax at a special rate even though the special-rate column reflected nil income. The resulting computation reflected an apparent mistake in the intimation. Although the assessee had filed the return negligently, the assessing authority was still required to examine whether the same income had been subjected to tax twice. In the interest of substantial justice, the rectification request could not be rejected without proper consideration on merits.

Conclusion: The matter was restored to the assessing authority to decide the rectification application on merits after giving the assessee an opportunity of hearing.

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