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    <title>1978 (1) TMI 74 - CALCUTTA High Court</title>
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    <description>Rectification under section 154 of the Income-tax Act is limited to an obvious, patent and self-evident mistake and cannot be used where the issue depends on detailed fact-finding or competing legal interpretations. The assessee&#039;s claim that its piling operations amounted to manufacture or processing, and that it was wholly or mainly engaged in such activity for rebate purposes under the Finance Act, 1964, required examination of the business facts and was open to more than one view. No mistake apparent from the record was shown, so rectification was not permissible and the matter was decided against the assessee.</description>
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    <pubDate>Fri, 27 Jan 1978 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=38453</link>
      <description>Rectification under section 154 of the Income-tax Act is limited to an obvious, patent and self-evident mistake and cannot be used where the issue depends on detailed fact-finding or competing legal interpretations. The assessee&#039;s claim that its piling operations amounted to manufacture or processing, and that it was wholly or mainly engaged in such activity for rebate purposes under the Finance Act, 1964, required examination of the business facts and was open to more than one view. No mistake apparent from the record was shown, so rectification was not permissible and the matter was decided against the assessee.</description>
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      <pubDate>Fri, 27 Jan 1978 00:00:00 +0530</pubDate>
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