https://www.taxtmi.com/caselaws?id=285479 Section 154 could not be used to reclassify refund interest under the Indo-Australia DTAA where the original treatment under Article 11 was sought to be led to Article 22. The classification issue required a fresh examination of the treaty position and was debatable, so it was not a patent mistake apparent from the record. The rectification order was therefore beyond the scope of section 154 and was quashed in favour of the assessee. en-us Wed, 02 Aug 2017 00:00:00 +0530 Tue, 14 Jan 2020 20:31:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285479 Section 154 could not be used to reclassify refund interest under the Indo-Australia DTAA where the original treatment under Article 11 was sought to be led to Article 22. The classification issue required a fresh examination of the treaty position and was debatable, so it was not a patent mistake apparent from the record. The rectification order was therefore beyond the scope of section 154 and was quashed in favour of the assessee. Case-Laws Income Tax Wed, 02 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285479