Rectification under section 154 requires record-based error; section 84 relief cannot be granted without existing factual material.

Rectification under section 154 of the Income-tax Act is confined to mistakes apparent from the record and cannot be used to grant relief under section 84 unless the assessment record already contains sufficient material to establish every statutory condition for that relief. The Court accepted that relevant material from the super profits tax record could form part of the income-tax record, but held that the material available did not show all facts necessary to satisfy section 84 when the assessment was completed. In the absence of such demonstrable record material, the omission to allow relief was not a rectifiable mistake, and the assessee's challenge failed.

---

---

Issues: Whether rectification under section 154 of the Income-tax Act, 1961 could be invoked to grant relief under section 84 of the Act when the assessment record did not contain sufficient material to establish the statutory conditions for that relief.

Analysis: Section 154 permits amendment only to rectify a mistake apparent from the record. Relief under section 84 depended on satisfaction of several factual conditions, and the Income-tax Officer could grant such relief only if the assessment record contained clear data enabling those conditions to be examined. The Court accepted that material from the super profits tax record could, to the extent relevant, form part of the income-tax record. However, the material shown did not establish that all facts necessary to satisfy section 84 were available on the record when the assessment was completed. In the absence of such material, omission to grant the relief could not be treated as a mistake apparent from the record.

Conclusion: Rectification under section 154 could not be used to grant section 84 relief on the facts, and the assessee's challenge failed.

Ratio Decidendi: Rectification is available only where the record itself contains sufficient material to show an apparent mistake; a statutory relief requiring proof of multiple factual conditions cannot be allowed under section 154 unless those conditions are demonstrable from the existing record.

---