https://www.taxtmi.com/caselaws?id=451048 The Gujarat HC upheld ITAT's decision that addition of surrendered income to book profit under Section 115JB cannot be corrected through rectification proceedings under Section 154. The court held that inclusion of disclosed income in book profit calculations requires detailed reasoning and debate, making it a debatable issue rather than a mistake apparent on record. Since the matter involved uncertainty and contentious arguments, the Assessing Officer lacked jurisdiction to invoke Section 154 powers. The HC confirmed that both the Assessing Officer and CIT(A) acted beyond their authority in attempting rectification. Decision favored the assessee against revenue. en-us Tue, 12 Mar 2024 00:00:00 +0530 Tue, 19 Mar 2024 09:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451048 The Gujarat HC upheld ITAT's decision that addition of surrendered income to book profit under Section 115JB cannot be corrected through rectification proceedings under Section 154. The court held that inclusion of disclosed income in book profit calculations requires detailed reasoning and debate, making it a debatable issue rather than a mistake apparent on record. Since the matter involved uncertainty and contentious arguments, the Assessing Officer lacked jurisdiction to invoke Section 154 powers. The HC confirmed that both the Assessing Officer and CIT(A) acted beyond their authority in attempting rectification. Decision favored the assessee against revenue. Case-Laws Income Tax Tue, 12 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451048