Rectification under section 154 is limited to apparent mistakes; disputed inclusion of interest income could not be corrected.

Rectification under section 154 is confined to mistakes apparent, obvious and self-evident from the record, and cannot be used where the alleged error requires factual reappraisal or resolution of debatable arguments. On that footing, the claim that interest income had wrongly entered the return and assessment was not a patent mistake on the face of the record. The rectification request was therefore not maintainable, and the rejection of relief was upheld against the assessee.

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Issues: Whether rectification under section 154 of the Income-tax Act, 1961 was maintainable for deletion of an amount of interest income alleged to have been wrongly included in the return and assessment.

Analysis: Rectification under section 154 is confined to mistakes that are apparent, obvious and self-evident from the record. Where the alleged error can be established only by re-examination of facts or by entering into detailed and debatable arguments, it falls outside the limited scope of rectification. The claim that the interest income was wrongly crept into the return required factual reappraisal and was not a patent mistake on the face of the record.

Conclusion: The rectification application was not maintainable and the rejection of relief was upheld against the assessee.

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