https://www.taxtmi.com/caselaws?id=37633 Rectification under section 154 of the Income-tax Act, 1961 is confined to an obvious, patent and self-evident mistake apparent from the record, and it cannot be used where correction depends on interpretation, factual examination, or two possible legal views. On that test, the proposed correction of the tax notice was impermissible because the export-profit deduction question under the Finance Act, 1965 turned on whether sale proceeds from import entitlement were profits derived from export, and the rebate question turned on whether manufacture of aluminium utensils amounted to manufacture or production of aluminium. Both issues were debatable, so section 154 could not be invoked and the notice was without jurisdiction. en-us Wed, 18 Feb 1976 00:00:00 +0530 Wed, 31 Mar 2010 10:55:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37633 Rectification under section 154 of the Income-tax Act, 1961 is confined to an obvious, patent and self-evident mistake apparent from the record, and it cannot be used where correction depends on interpretation, factual examination, or two possible legal views. On that test, the proposed correction of the tax notice was impermissible because the export-profit deduction question under the Finance Act, 1965 turned on whether sale proceeds from import entitlement were profits derived from export, and the rebate question turned on whether manufacture of aluminium utensils amounted to manufacture or production of aluminium. Both issues were debatable, so section 154 could not be invoked and the notice was without jurisdiction. Case-Laws Income Tax Wed, 18 Feb 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37633