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Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors.
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Rectification under section 154 cannot withdraw a deduction under section 80P(2)(a)(i) that was expressly claimed and accepted after scrutiny where its eligibility involves a debatable statutory question. Interest income was claimed as business income attributable to a co-operative society's activities and allowed after verification under section 143(3). The subsequent view that the claim was inconsistent with decisions concerning section 80P(2)(d) required reconsideration of an already examined claim, rather than correction of a mistake apparent from the record. The rectification and appellate orders reversing the deduction were therefore set aside.
Rectification under section 154 cannot withdraw a deduction under section 80P(2)(a)(i) that was expressly claimed and accepted after scrutiny where its eligibility involves a debatable statutory question. Interest income was claimed as business income attributable to a co-operative society's activities and allowed after verification under section 143(3). The subsequent view that the claim was inconsistent with decisions concerning section 80P(2)(d) required reconsideration of an already examined claim, rather than correction of a mistake apparent from the record. The rectification and appellate orders reversing the deduction were therefore set aside.
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