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ITAT held that rectification under section 154 cannot be used to recharacterise survey disclosure accepted in scrutiny assessment as business income into unexplained money under section 69A and taxed under section 115BBE. The amount had been stated during survey as on-money receipts from business activity, credited in the regular books, and accepted in the original section 143(3) assessment as business income. Because changing its character would require fresh factual appraisal and a new determination on section 69A, the issue was debatable and outside the limited scope of rectification. The rectification order was therefore unsustainable.
ITAT held that rectification under section 154 cannot be used to recharacterise survey disclosure accepted in scrutiny assessment as business income into unexplained money under section 69A and taxed under section 115BBE. The amount had been stated during survey as on-money receipts from business activity, credited in the regular books, and accepted in the original section 143(3) assessment as business income. Because changing its character would require fresh factual appraisal and a new determination on section 69A, the issue was debatable and outside the limited scope of rectification. The rectification order was therefore unsustainable.
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