https://www.taxtmi.com/caselaws?id=433571 The ITAT Pune ruled in favor of the assessee, dismissing the A.O's order under section 154. The Tribunal found that the rectification to withdraw excess interest under section 244A was not a mistake apparent from the record, as differing interpretations of "regular assessment" existed. The CIT(A)'s decision was upheld, highlighting that rectification is permissible only for obvious and patent mistakes, not debatable legal points. The Tribunal did not address the CBDT Circulars' monetary limits issue, focusing instead on the rectification and interpretation of "regular assessment" for interest eligibility under section 244A. en-us Tue, 31 Jan 2023 00:00:00 +0530 Fri, 20 Dec 2024 11:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433571 The ITAT Pune ruled in favor of the assessee, dismissing the A.O's order under section 154. The Tribunal found that the rectification to withdraw excess interest under section 244A was not a mistake apparent from the record, as differing interpretations of "regular assessment" existed. The CIT(A)'s decision was upheld, highlighting that rectification is permissible only for obvious and patent mistakes, not debatable legal points. The Tribunal did not address the CBDT Circulars' monetary limits issue, focusing instead on the rectification and interpretation of "regular assessment" for interest eligibility under section 244A. Case-Laws Income Tax Tue, 31 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433571