https://www.taxtmi.com/caselaws?id=36150 Rectification under Section 154 cannot be used to resolve a debatable question whether development rebate must be deducted in computing profits attributable to the soda ash business for special rebate under Paragraph F of the First Schedule to the Finance Act, 1965. Special rebate and Section 80E were treated as in pari materia, requiring net taxable profits after admissible deductions and allowances rather than gross commercial profits. However, conflicting judicial views on the treatment of development rebate meant that the issue required legal argument and could not constitute a mistake apparent from the record. The Section 154 notice was therefore unsustainable. en-us Thu, 16 Aug 1979 00:00:00 +0530 Fri, 19 Mar 2010 16:10:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36150 Rectification under Section 154 cannot be used to resolve a debatable question whether development rebate must be deducted in computing profits attributable to the soda ash business for special rebate under Paragraph F of the First Schedule to the Finance Act, 1965. Special rebate and Section 80E were treated as in pari materia, requiring net taxable profits after admissible deductions and allowances rather than gross commercial profits. However, conflicting judicial views on the treatment of development rebate meant that the issue required legal argument and could not constitute a mistake apparent from the record. The Section 154 notice was therefore unsustainable. Case-Laws Income Tax Thu, 16 Aug 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36150