Rectification cannot reclassify accepted business receipts as unexplained income when the issue needs fresh fact-finding.

Rectification under section 154 cannot be used to reclassify survey-disclosed receipts, already accepted in scrutiny assessment as business income, as unexplained income under section 69A read with section 115BBE. Where the character of receipts had been accepted after assessment under section 143(3), altering that view required fresh examination of facts and a reappraisal of the nature of the receipts, which falls outside the limited scope of rectification. A point requiring detailed reasoning or capable of more than one view is not a mistake apparent from the record. The ITAT held the rectification order unsustainable and upheld the assessee's treatment.

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Issues: Whether the Assessing Officer could invoke rectification under section 154 to recharacterise survey-disclosed receipts, earlier accepted in scrutiny assessment as business income, as unexplained income under section 69A liable to tax under section 115BBE.

Analysis: The disclosed amount had been stated during survey to represent on-money receipts arising from the assessee's business activity, was subsequently credited in the books, and was accepted in the original assessment under section 143(3) as business income. Reopening that characterization through rectification required fresh evaluation of facts and the nature of the receipts, which went beyond the limited scope of section 154. A matter capable of more than one view and requiring a long-drawn process of reasoning cannot be treated as a mistake apparent from the record, and rectification cannot be used as a substitute for review or reappraisal.

Conclusion: The rectification order under section 154 was unsustainable, and the reclassification of the income as unexplained income under section 69A read with section 115BBE was not justified. The issue was decided in favour of the assessee.

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