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    <title>2014 (7) TMI 595 - ITAT MUMBAI</title>
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    <description>Rectification under section 154 cannot be used to enhance assessed income without prior notice and a reasonable opportunity of hearing, and it is unavailable where the issue is debatable or requires elaborate reasoning. On those facts, the fresh addition made in rectification was unsustainable and stood deleted. Interest under section 234B also could not be introduced through rectification, especially where the same levy had already been negatived in the quantum order for the year. The rectification order was therefore not sustained on either issue, and the assessee succeeded on both the enhanced addition and the interest levy.</description>
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    <pubDate>Wed, 09 Jul 2014 00:00:00 +0530</pubDate>
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      <title>2014 (7) TMI 595 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=249559</link>
      <description>Rectification under section 154 cannot be used to enhance assessed income without prior notice and a reasonable opportunity of hearing, and it is unavailable where the issue is debatable or requires elaborate reasoning. On those facts, the fresh addition made in rectification was unsustainable and stood deleted. Interest under section 234B also could not be introduced through rectification, especially where the same levy had already been negatived in the quantum order for the year. The rectification order was therefore not sustained on either issue, and the assessee succeeded on both the enhanced addition and the interest levy.</description>
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      <pubDate>Wed, 09 Jul 2014 00:00:00 +0530</pubDate>
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