https://www.taxtmi.com/caselaws?id=277027 Rectification power under section 35 of the Income-tax Act was confined to mistakes apparent from the record and could not be used to determine debatable questions requiring fresh factual inquiry or statutory interpretation. On that basis, additional tax sought on the footing of excess dividend was held beyond the scope of rectification because the statutory basis for the levy was not self-evident on the record. The same limit applied to penal interest under section 18A(8), since liability depended on factual questions about anticipated assessable income and advance tax, making rectification jurisdiction unavailable. The rectification proceedings and the revisional orders confirming them were quashed. en-us Mon, 31 Oct 1955 00:00:00 +0530 Thu, 22 Nov 2018 13:21:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277027 Rectification power under section 35 of the Income-tax Act was confined to mistakes apparent from the record and could not be used to determine debatable questions requiring fresh factual inquiry or statutory interpretation. On that basis, additional tax sought on the footing of excess dividend was held beyond the scope of rectification because the statutory basis for the levy was not self-evident on the record. The same limit applied to penal interest under section 18A(8), since liability depended on factual questions about anticipated assessable income and advance tax, making rectification jurisdiction unavailable. The rectification proceedings and the revisional orders confirming them were quashed. Case-Laws Income Tax Mon, 31 Oct 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277027