https://www.taxtmi.com/caselaws?id=26082 Rectification under section 154 could not be used to revise the grossing-up of dividend income where the issue depended on whether carried-forward losses of the dividend-paying company fell within the proviso to section 16(2) of the Indian Income-tax Act, 1922. The Court noted that the provision referred to specified categories such as profits, income not taxable, and amounts attributable to allowances, and that a carried-forward business loss did not clearly fit those terms. Because the question was reasonably debatable and not an obvious mistake, the rectification order was unsustainable and the issue was decided in favour of the assessee. en-us Mon, 23 Jun 1986 00:00:00 +0530 Tue, 02 Feb 2010 16:16:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26082 Rectification under section 154 could not be used to revise the grossing-up of dividend income where the issue depended on whether carried-forward losses of the dividend-paying company fell within the proviso to section 16(2) of the Indian Income-tax Act, 1922. The Court noted that the provision referred to specified categories such as profits, income not taxable, and amounts attributable to allowances, and that a carried-forward business loss did not clearly fit those terms. Because the question was reasonably debatable and not an obvious mistake, the rectification order was unsustainable and the issue was decided in favour of the assessee. Case-Laws Income Tax Mon, 23 Jun 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26082