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ITAT affirmed the CIT(A)'s allowance of rectification under s.154, holding that the AO's refusal to grant deduction under s.36(1)(vii) for non-rural debts written off constituted a mistake apparent from record. The Tribunal accepted that a subsequent HC decision clarified the correct legal position and, consistent with administrative guidance recognizing subsequent SC interpretations as rectifiable errors, the assessment completed without that precedent was defective. The AO's rejection was overturned, the rectification granted, and the deduction allowed to the assessee. The appeal by the revenue was dismissed.
ITAT affirmed the CIT(A)'s allowance of rectification under s.154, holding that the AO's refusal to grant deduction under s.36(1)(vii) for non-rural debts written off constituted a mistake apparent from record. The Tribunal accepted that a subsequent HC decision clarified the correct legal position and, consistent with administrative guidance recognizing subsequent SC interpretations as rectifiable errors, the assessment completed without that precedent was defective. The AO's rejection was overturned, the rectification granted, and the deduction allowed to the assessee. The appeal by the revenue was dismissed.
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