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    <title>2010 (7) TMI 438 - ITAT, MUMBAI</title>
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    <description>Section 154 could not be used to seek a further tax credit for rental income already assessed in the tenant-company&#039;s hands, because the assessee and the tenant were separate taxable entities and the alleged double-credit issue was at least highly debatable. The earlier authority relied on involved a different statutory setting and a prohibition on double assessment between distinct persons under that regime, which did not apply here. Since credit for tax paid by the tenant-company had already been allowed in its assessment and no clear statutory basis supported an additional credit in the assessee&#039;s hands, the non-grant of such credit was not a patent mistake apparent from the record. The rectification claim was therefore rightly rejected.</description>
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    <pubDate>Fri, 16 Jul 2010 00:00:00 +0530</pubDate>
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      <title>2010 (7) TMI 438 - ITAT, MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=202879</link>
      <description>Section 154 could not be used to seek a further tax credit for rental income already assessed in the tenant-company&#039;s hands, because the assessee and the tenant were separate taxable entities and the alleged double-credit issue was at least highly debatable. The earlier authority relied on involved a different statutory setting and a prohibition on double assessment between distinct persons under that regime, which did not apply here. Since credit for tax paid by the tenant-company had already been allowed in its assessment and no clear statutory basis supported an additional credit in the assessee&#039;s hands, the non-grant of such credit was not a patent mistake apparent from the record. The rectification claim was therefore rightly rejected.</description>
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      <pubDate>Fri, 16 Jul 2010 00:00:00 +0530</pubDate>
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