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    <title>2001 (1) TMI 237 - ITAT NAGPUR</title>
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    <description>Rectification under section 154 is confined to patent mistakes apparent from the record and cannot be used to reopen a debatable question on the levy of interest under sections 234A, 234B and 234C. Where the levy had been deleted and was later sought to be restored by rectification, the issue was not an obvious error but a matter on which two views were possible, so section 154 was not available. An adverse rectification order also requires a reasonable opportunity of hearing; absence of such opportunity renders the amendment unsustainable on natural justice grounds.</description>
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      <link>https://www.taxtmi.com/caselaws?id=70838</link>
      <description>Rectification under section 154 is confined to patent mistakes apparent from the record and cannot be used to reopen a debatable question on the levy of interest under sections 234A, 234B and 234C. Where the levy had been deleted and was later sought to be restored by rectification, the issue was not an obvious error but a matter on which two views were possible, so section 154 was not available. An adverse rectification order also requires a reasonable opportunity of hearing; absence of such opportunity renders the amendment unsustainable on natural justice grounds.</description>
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      <pubDate>Wed, 10 Jan 2001 00:00:00 +0530</pubDate>
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