https://www.taxtmi.com/caselaws?id=377049 Rectification under Section 154 of the Income-tax Act, 1961 cannot be used where the proposed correction depends on a debatable legal issue and is not a mistake apparent from the record. The dispute concerned whether the deduction under Section 80-IA could be reduced while computing deduction under Section 80HHC, but the legal position on that inter se adjustment was not conclusively settled at the time of rectification. The HC held that such controversy fell outside the scope of Section 154, upheld the Tribunal's view, and found that no substantial question of law arose. The Revenue's appeal therefore failed. en-us Fri, 08 Mar 2019 00:00:00 +0530 Wed, 20 Mar 2019 08:46:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=377049 Rectification under Section 154 of the Income-tax Act, 1961 cannot be used where the proposed correction depends on a debatable legal issue and is not a mistake apparent from the record. The dispute concerned whether the deduction under Section 80-IA could be reduced while computing deduction under Section 80HHC, but the legal position on that inter se adjustment was not conclusively settled at the time of rectification. The HC held that such controversy fell outside the scope of Section 154, upheld the Tribunal's view, and found that no substantial question of law arose. The Revenue's appeal therefore failed. Case-Laws Income Tax Fri, 08 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=377049