Rectification under section 154 cannot be used to decide debatable issues; an improper addition was quashed.

Rectification under section 154 is limited to correcting only a mistake apparent from the record, and it cannot be used where the issue requires debatable factual or legal examination. On the recorded facts, the credit of rent payable to the capital account did not disclose an obvious mistake justifying an addition through rectification. The rectification jurisdiction was therefore improperly invoked, and the rectification order was quashed.

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Issues: Whether the rectification order under section 154 of the Income-tax Act, 1961, adding rent payable credited to the capital account, was sustainable in the absence of a mistake apparent from the record.

Analysis: Rectification under section 154 is confined to correcting an obvious mistake apparent from the record. On the facts recorded, there was no material demonstrating that the amount credited as rent payable constituted an addition warranting rectification, and the issue involved debatable factual and legal considerations beyond the scope of section 154.

Conclusion: The exercise of rectification jurisdiction was held to be improper and the rectification order was quashed.

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