Rectification u/s 154 without careful consideration of the facts and circumstances of the case, and the basic issue whether section 154 could be invoked at all

Rectification u/s 154 without careful consideration of the facts and circumstances of the case, and the basic issue whether section 154 could be invoked at all https://www.taxtmi.com/circulars?id=10072 Rectification under section 154 is confined to mistakes apparent from the record and must not be used where the error relies on extraneous evidence or extensive reasoning. Reopening under section 147(b) is susceptible if based only on change of opinion; audit scrutiny notes as "information" are legally contested. Intervention under section 263 is recommended where assessments are unappealed and significant tax is involved. ITOs should assess remedial options carefully, consult IACs, and avoid measures that risk loss of revenue. en-us Thu, 09 Aug 1973 00:00:00 +0530 Fri, 17 Jun 2011 18:14:00 +0530 TaxTMI RSS Generator Rectification u/s 154 without careful consideration of the facts and circumstances of the case, and the basic issue whether section 154 could be invoked at all https://www.taxtmi.com/circulars?id=10072 Rectification under section 154 is confined to mistakes apparent from the record and must not be used where the error relies on extraneous evidence or extensive reasoning. Reopening under section 147(b) is susceptible if based only on change of opinion; audit scrutiny notes as "information" are legally contested. Intervention under section 263 is recommended where assessments are unappealed and significant tax is involved. ITOs should assess remedial options carefully, consult IACs, and avoid measures that risk loss of revenue. Circulars Income Tax Thu, 09 Aug 1973 00:00:00 +0530 https://www.taxtmi.com/circulars?id=10072