https://www.taxtmi.com/caselaws?id=751563 ITAT Delhi held that AO's order u/s 154 attempting to revise previously accepted source of investment was invalid. The tribunal ruled that changing a view on source of funds, which was accepted in original assessment with proper documentary evidence, cannot be rectified u/s 154 as it's not a mistake apparent from record. Following SC precedent in Volkart Brothers case, the tribunal emphasized that rectifiable mistakes must be obvious and patent, not requiring lengthy reasoning or involving debatable points of law. The AO's attempt to change his earlier decision under garb of rectification was impermissible. Assessee's appeal was allowed and impugned order was quashed. en-us Tue, 16 Apr 2024 00:00:00 +0530 Fri, 19 Apr 2024 14:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751563 ITAT Delhi held that AO's order u/s 154 attempting to revise previously accepted source of investment was invalid. The tribunal ruled that changing a view on source of funds, which was accepted in original assessment with proper documentary evidence, cannot be rectified u/s 154 as it's not a mistake apparent from record. Following SC precedent in Volkart Brothers case, the tribunal emphasized that rectifiable mistakes must be obvious and patent, not requiring lengthy reasoning or involving debatable points of law. The AO's attempt to change his earlier decision under garb of rectification was impermissible. Assessee's appeal was allowed and impugned order was quashed. Case-Laws Income Tax Tue, 16 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751563