https://www.taxtmi.com/caselaws?id=313816 ITAT Raipur ruled against the assessee regarding rectification under Section 154 for disallowance of delayed ESI/PF employee contributions. The tribunal held that rectification is only permissible for patent, apparent mistakes from record, not debatable legal issues. Since the deductibility of delayed employee contributions under Section 36(1)(va) read with Section 43B was subject to different judicial interpretations before the SC decision in Checkmate Services, the matter involved legal debate rather than an obvious error. The disallowance could not be rectified under Section 154's limited scope. en-us Thu, 10 Aug 2023 00:00:00 +0530 Fri, 03 May 2024 15:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313816 ITAT Raipur ruled against the assessee regarding rectification under Section 154 for disallowance of delayed ESI/PF employee contributions. The tribunal held that rectification is only permissible for patent, apparent mistakes from record, not debatable legal issues. Since the deductibility of delayed employee contributions under Section 36(1)(va) read with Section 43B was subject to different judicial interpretations before the SC decision in Checkmate Services, the matter involved legal debate rather than an obvious error. The disallowance could not be rectified under Section 154's limited scope. Case-Laws Income Tax Thu, 10 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313816