Mistake apparent from record limits section 154 rectification; debatable issues or external material cannot justify correction.

Rectification under section 154 of the Income-tax Act is limited to a mistake apparent from the record, meaning an error visible on the face of the record without resort to external material or competing views on merits. Where the alleged error depends on further examination or debatable reasoning, section 154 cannot be used. On the facts stated, no patent mistake was shown from the record, so the rectification order was not sustainable and the assessee succeeded on that issue.

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Issues: Whether rectification under section 154 of the Income-tax Act, 1961 was justified on the ground of a mistake apparent from the record.

Analysis: Rectification under section 154 is confined to an error that is evident from a look at the record itself. A mistake which requires reference to material outside the record or involves competing views on the merits cannot be treated as an apparent mistake. On the facts, no such patent error was shown on the record.

Conclusion: The rectification order under section 154 was not sustainable and the assessee succeeded on the issue.

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