Section 154 rectification cannot revisit profitability or comparative claims requiring enquiry; application held not maintainable.

Rectification under Section 154 is limited to mistakes apparent from the record and cannot be used for a subjective reappraisal of business profitability or a comparison with other assessees that requires detailed enquiry. The appellate authority's reasoning did not unsettle the Assessing Officer's view that the claim fell outside the narrow scope of rectification. Reliance on Goetze (India) Ltd. was held inapposite because that decision did not concern rectification proceedings under Section 154. The rectification application was therefore not maintainable, and the Revenue's challenge succeeded.

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Issues: Whether the assessee's rectification application under Section 154 of the Income-tax Act, 1961 was maintainable on the facts of the case.

Analysis: Rectification under Section 154 is confined to mistakes apparent from the record and does not permit a subjective reappraisal of business profitability or a comparison with other assessees requiring detailed enquiry. The appellate authority's reasoning did not dislodge the Assessing Officer's finding that the claim required examination beyond the scope of rectification. The reliance on Goetze (India) Ltd. was held to be inapposite because it did not deal with rectification proceedings under Section 154.

Conclusion: The rectification application was held to be not maintainable, and the Revenue's challenge succeeded.

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