Rectification under section 154 cannot be used to add debatable depreciation claims or extra shift allowance.

A rectification order under section 154 cannot be used to introduce depreciation or extra shift allowance where no depreciation claim was made in the original assessment and the issue is debatable. A matter that requires debate or fresh computation is not a mistake apparent from the record, so rectification is outside section 154. The later rectification order therefore could not be sustained and was cancelled.

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Issues: Whether the rectification order passed under section 154 could be sustained when the alleged error in not allowing depreciation and extra shift allowance was not a mistake apparent from the record.

Analysis: The assessment had been completed without depreciation because no claim was made by the assessee. The later rectification orders were passed to alter the computation of income by allowing depreciation and then extra shift allowance. The matter had already been found to be highly debatable, and a debatable question cannot be corrected under section 154. On the same reasoning, the subsequent rectification order could not stand.

Conclusion: The rectification order was invalid and was rightly cancelled.

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