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    <title>1994 (2) TMI 23 - GUJARAT High Court</title>
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    <description>Special surcharge on unearned income had to be computed only on the unearned income included in assessed total income, not on gross unearned income. The court treated the surcharge provision as tied to the income component actually forming part of total income and held the Revenue could not enlarge the base beyond that figure. The computation dispute also depended on interpretation of the governing provision, making it debatable rather than an obvious error. Rectification was therefore not permissible under section 154 because there was no mistake apparent from the record, and the point was decided in favour of the assessee.</description>
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    <pubDate>Wed, 23 Feb 1994 00:00:00 +0530</pubDate>
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      <title>1994 (2) TMI 23 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=19753</link>
      <description>Special surcharge on unearned income had to be computed only on the unearned income included in assessed total income, not on gross unearned income. The court treated the surcharge provision as tied to the income component actually forming part of total income and held the Revenue could not enlarge the base beyond that figure. The computation dispute also depended on interpretation of the governing provision, making it debatable rather than an obvious error. Rectification was therefore not permissible under section 154 because there was no mistake apparent from the record, and the point was decided in favour of the assessee.</description>
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      <pubDate>Wed, 23 Feb 1994 00:00:00 +0530</pubDate>
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