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    <title>1965 (9) TMI 10 - CALCUTTA High Court</title>
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    <description>Rectification under section 35 of the Income-tax Act, 1922 may be based on the assessee&#039;s own records, including material from other assessment years, where needed to verify an apparent mistake. An error is apparent when the relevant facts are admitted or otherwise self-evident from the record, leaving no real scope for debate. Sections 34 and 35 were treated as distinct powers, but not mutually exclusive, so rectification could proceed if the jurisdictional conditions were met. In pending matters, section 154 of the Income-tax Act, 1961 could apply retrospectively as procedural law. A certificate under article 133 was not justified because no substantial question of law was shown.</description>
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    <pubDate>Fri, 10 Sep 1965 00:00:00 +0530</pubDate>
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      <title>1965 (9) TMI 10 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6777</link>
      <description>Rectification under section 35 of the Income-tax Act, 1922 may be based on the assessee&#039;s own records, including material from other assessment years, where needed to verify an apparent mistake. An error is apparent when the relevant facts are admitted or otherwise self-evident from the record, leaving no real scope for debate. Sections 34 and 35 were treated as distinct powers, but not mutually exclusive, so rectification could proceed if the jurisdictional conditions were met. In pending matters, section 154 of the Income-tax Act, 1961 could apply retrospectively as procedural law. A certificate under article 133 was not justified because no substantial question of law was shown.</description>
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      <pubDate>Fri, 10 Sep 1965 00:00:00 +0530</pubDate>
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