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    <title>2004 (7) TMI 79 - CALCUTTA High Court</title>
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    <description>Rectification under section 154 is limited to obvious, patent mistakes apparent on the face of the record and cannot be used to revisit a concluded settlement order on a debatable issue. A claimed waiver of interest under sections 234A, 234B and 234C could not be treated as a mistake apparent from the record because it would require examination of the settlement basis, the effect of a Board circular, and later legal developments. The finality of an order under section 245D(4) could not be displaced through a disguised review. The Calcutta HC therefore held that the attempted reopening was not sustainable and failed.</description>
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      <title>2004 (7) TMI 79 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=10864</link>
      <description>Rectification under section 154 is limited to obvious, patent mistakes apparent on the face of the record and cannot be used to revisit a concluded settlement order on a debatable issue. A claimed waiver of interest under sections 234A, 234B and 234C could not be treated as a mistake apparent from the record because it would require examination of the settlement basis, the effect of a Board circular, and later legal developments. The finality of an order under section 245D(4) could not be displaced through a disguised review. The Calcutta HC therefore held that the attempted reopening was not sustainable and failed.</description>
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