Rectification jurisdiction is limited to apparent mistakes and cannot resolve debatable tax computation issues under the Income-tax Act.

Rectification under section 154 is limited to mistakes apparent from the record, meaning obvious errors that do not require extended reasoning or resolution of debatable issues. Where the alleged error concerns the computation of capital employed under section 15C and the treatment of initial depreciation in written down value, the dispute turns on competing statutory interpretations rather than a patent mistake. In that setting, omission to consider a relevant provision does not convert the issue into an apparent error. The rectification jurisdiction cannot be used to decide contested questions of law, so notices and resulting rectification orders would be outside section 154.

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Issues: Whether the notices and rectification orders under section 154 of the Income-tax Act, 1961, could stand where the alleged error involved the computation of capital employed under section 15C and depended upon the treatment of initial depreciation in the written down value of assets.

Analysis: The rectification power under section 154 is confined to mistakes apparent from the record, that is, glaring, obvious or self-evident errors which do not require a long drawn process of reasoning or the resolution of debatable questions. The computation dispute turned on the interaction between section 15C, the capital computation rules, section 10(2)(vi), section 10(5), and the treatment of initial depreciation. The question was not a patent arithmetical slip but one involving substantial interpretative controversy. The omission to consider the relevant statutory provision also meant that the supposed error could not be treated as apparent on the face of the record.

Conclusion: The rectification was beyond the scope of section 154 and the notices and resultant orders were liable to be quashed.

Ratio Decidendi: A mistake is not apparent from the record if its identification depends on a contested interpretation of statutory provisions or a detailed reasoning process, and rectification jurisdiction cannot be used to decide such debatable issues.

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