https://www.taxtmi.com/caselaws?id=21054 A question on whether a deposit under the Companies Deposits (Surcharge on Income-tax) Scheme, 1976, could be treated as payment of surcharge for computing chargeable profits under the Companies (Profits) Surtax Act, 1964, was held to be debatable. Because conflicting Tribunal views existed, and a Special Bench had taken the view that such a deposit could not be equated with surcharge payment, the issue was not a patent error apparent from the record. A matter on which two reasonable views are possible cannot be corrected through rectification proceedings. The rectification order was therefore unsustainable and the issue was answered in favour of the assessee. en-us Tue, 06 Mar 1990 00:00:00 +0530 Thu, 19 Nov 2009 17:10:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21054 A question on whether a deposit under the Companies Deposits (Surcharge on Income-tax) Scheme, 1976, could be treated as payment of surcharge for computing chargeable profits under the Companies (Profits) Surtax Act, 1964, was held to be debatable. Because conflicting Tribunal views existed, and a Special Bench had taken the view that such a deposit could not be equated with surcharge payment, the issue was not a patent error apparent from the record. A matter on which two reasonable views are possible cannot be corrected through rectification proceedings. The rectification order was therefore unsustainable and the issue was answered in favour of the assessee. Case-Laws Income Tax Tue, 06 Mar 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21054