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    <title>1976 (4) TMI 14 - MADRAS High Court</title>
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    <description>Additional surcharge was held leviable on a co-operative society&#039;s exempt business income under the Finance Act, 1963, because the charging provision extended to residual income and the later Supreme Court interpretation of the same scheme was applied; the issue was decided for the Revenue. Rectification under section 154 was refused because the alleged error depended on a debatable construction of the taxing provision, and section 154 is confined to obvious, patent mistakes not requiring detailed reasoning or open to two reasonable views; this issue was decided for the assessee. The reference was thus answered by upholding the surcharge in principle but denying rectification.</description>
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    <pubDate>Tue, 06 Apr 1976 00:00:00 +0530</pubDate>
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      <title>1976 (4) TMI 14 - MADRAS High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=38542</link>
      <description>Additional surcharge was held leviable on a co-operative society&#039;s exempt business income under the Finance Act, 1963, because the charging provision extended to residual income and the later Supreme Court interpretation of the same scheme was applied; the issue was decided for the Revenue. Rectification under section 154 was refused because the alleged error depended on a debatable construction of the taxing provision, and section 154 is confined to obvious, patent mistakes not requiring detailed reasoning or open to two reasonable views; this issue was decided for the assessee. The reference was thus answered by upholding the surcharge in principle but denying rectification.</description>
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      <pubDate>Tue, 06 Apr 1976 00:00:00 +0530</pubDate>
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