Rectification u/s 154 - levy of interest u/s 234D of the Act...

Rectification u/s 154 - levy of interest u/s 234D of the Act from the date of grant of refund instead of date of receipt of cheque of refund, renders the issue to be debatable issue - the present case clearly falls beyond the ambit of the expression “mistake apparent from the record”, and thus, the rectification order dated 14/03/2017 passed under section 154 of the Act is set aside. - AT