https://www.taxtmi.com/caselaws?id=185186 A retrospective deeming proviso to section 18A(6) was treated as having vested the discretion to reduce or waive penal interest at the time of the original assessment. On that basis, the Income-tax Officer could not later invoke rectification under section 35 merely because interest had not been charged initially, since the omission was not an apparent error. The revisional order sustaining the rectification also disclosed an apparent error because it wrongly rejected the jurisdictional objection. The rectification order and the revisional order were therefore liable to be quashed in certiorari. en-us Thu, 13 Nov 1958 00:00:00 +0530 Wed, 03 Aug 2016 11:04:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185186 A retrospective deeming proviso to section 18A(6) was treated as having vested the discretion to reduce or waive penal interest at the time of the original assessment. On that basis, the Income-tax Officer could not later invoke rectification under section 35 merely because interest had not been charged initially, since the omission was not an apparent error. The revisional order sustaining the rectification also disclosed an apparent error because it wrongly rejected the jurisdictional objection. The rectification order and the revisional order were therefore liable to be quashed in certiorari. Case-Laws Income Tax Thu, 13 Nov 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185186