Apparent mistake correction and remand on fixed deposit interest treatment under section 80IC for fresh adjudication.

A patent typographical error in the assessment record was corrected because the recorded interest figure did not match the amount reflected in the assessment order, and the Assessing Officer was directed to substitute the correct figure. The question whether fixed deposit interest kept as margin money for bank guarantees linked to raw material procurement qualified as business income, and whether netting could be claimed if deduction under section 80IC was unavailable, was sent back to the CIT(A) for fresh adjudication in line with the Tribunal's earlier order in the assessee's own case. The matter was thus partly corrected and partly remanded.

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Issues: (i) Whether the typographical error in the interest amount recorded in the assessment proceedings required correction. (ii) Whether the question of deduction on fixed deposit interest and the related claim for netting under section 80IC required fresh consideration.

Issue (i): Whether the typographical error in the interest amount recorded in the assessment proceedings required correction.

Analysis: The amount reflected in the assessment record was found to be Rs. 28,07,860/-, whereas the impugned order had mentioned Rs. 2,80,01,668/-. The error was apparent from the assessment order and could be corrected on the record.

Conclusion: The correction was allowed and the Assessing Officer was directed to substitute Rs. 28,07,860/- in place of Rs. 2,80,01,668/-.

Issue (ii): Whether the question of deduction on fixed deposit interest and the related claim for netting under section 80IC required fresh consideration.

Analysis: The dispute concerned whether interest on fixed deposits kept as margin money for bank guarantees linked to procurement of raw material formed part of business receipt and, if not eligible for deduction under section 80IC, whether only the net interest could be brought to tax. The matter was taken to be covered by the Tribunal's earlier order in the assessee's own case for the preceding year, and the issue was restored to the first appellate authority for decision in accordance with that order.

Conclusion: The issue was remitted to the CIT(A) for fresh adjudication in terms of the earlier Tribunal order.

Final Conclusion: The appeal resulted in partial substantive relief on the recorded mistake and a remand on the interest-income issue, with the overall appeal being disposed of in favour of the assessee for statistical purposes.

Ratio Decidendi: A patent mistake in the quantum recorded in the assessment order is rectifiable, and where the tax treatment of fixed deposit interest depends on factual verification of its business nexus, the issue may be restored for fresh adjudication in line with the earlier year's decision.

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