https://www.taxtmi.com/caselaws?id=37404 A mistaken allowance of set-off for unabsorbed development rebate relating to assets installed before 1 January 1958 was treated as a mistake apparent from the record and rectifiable under section 154. The statutory scheme distinguished between assets installed before and after 1 January 1958: carry forward of unabsorbed development rebate was available only within the limits set by the relevant provisions, including sections 33(2) and 33(3), and did not extend to the excluded pre-1958 class. Because the allowance contradicted that clear statutory restriction, no debatable interpretive issue arose, and rectification was upheld in favour of the revenue. en-us Mon, 22 Jan 1979 00:00:00 +0530 Mon, 29 Mar 2010 14:04:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37404 A mistaken allowance of set-off for unabsorbed development rebate relating to assets installed before 1 January 1958 was treated as a mistake apparent from the record and rectifiable under section 154. The statutory scheme distinguished between assets installed before and after 1 January 1958: carry forward of unabsorbed development rebate was available only within the limits set by the relevant provisions, including sections 33(2) and 33(3), and did not extend to the excluded pre-1958 class. Because the allowance contradicted that clear statutory restriction, no debatable interpretive issue arose, and rectification was upheld in favour of the revenue. Case-Laws Income Tax Mon, 22 Jan 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37404