https://www.taxtmi.com/caselaws?id=778463 ITAT Kolkata (AT) allowed the taxpayer's appeal, holding that rectification under s.154 is confined to obvious, patent mistakes apparent from the record and cannot be used to decide debatable legal or factual issues. The tribunal ruled that the allowability of warranty provisions is a debatable question on which two reasonable opinions can exist, and therefore the AO cannot invoke s.154 to alter the assessment; such matters require adjudication in appropriate proceedings, not summary rectification. en-us Mon, 15 Sep 2025 00:00:00 +0530 Wed, 17 Sep 2025 08:31:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778463 ITAT Kolkata (AT) allowed the taxpayer's appeal, holding that rectification under s.154 is confined to obvious, patent mistakes apparent from the record and cannot be used to decide debatable legal or factual issues. The tribunal ruled that the allowability of warranty provisions is a debatable question on which two reasonable opinions can exist, and therefore the AO cannot invoke s.154 to alter the assessment; such matters require adjudication in appropriate proceedings, not summary rectification. Case-Laws Income Tax Mon, 15 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778463