https://www.taxtmi.com/caselaws?id=27587 The High Court of GUJARAT upheld the Tribunal's decision regarding the interpretation and application of Section 154 of the Income-tax Act, 1961. The court emphasized that a "mistake apparent on the record" must be clear and not a debatable legal point. As the assessee did not contest the figures and calculations, the court concluded there was no basis for challenging the rectification proceedings. The court also found no grounds to dispute the adoption of dividend figures exceeding 10% of equity capital, as the assessee did not present an alternative perspective. The judgment underscored the significance of factual circumstances and parties' positions in tax-related determinations. en-us Tue, 17 Apr 1984 00:00:00 +0530 Sat, 13 Feb 2010 17:14:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27587 The High Court of GUJARAT upheld the Tribunal's decision regarding the interpretation and application of Section 154 of the Income-tax Act, 1961. The court emphasized that a "mistake apparent on the record" must be clear and not a debatable legal point. As the assessee did not contest the figures and calculations, the court concluded there was no basis for challenging the rectification proceedings. The court also found no grounds to dispute the adoption of dividend figures exceeding 10% of equity capital, as the assessee did not present an alternative perspective. The judgment underscored the significance of factual circumstances and parties' positions in tax-related determinations. Case-Laws Income Tax Tue, 17 Apr 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27587