https://www.taxtmi.com/caselaws?id=788976 Rectification under section 154 cannot be used to reargue a concluded claim against surcharge and education cess on income taxed under the India-USA tax treaty. A request that seeks reconsideration of the merits, rather than correction of a mistake apparent from the record, falls outside rectification jurisdiction. The text notes that the earlier appellate view had already rejected the treaty-based challenge and that the applicable precedent was against the assessee. On that basis, the rejection of the rectification application was upheld and the challenge to the levy failed. en-us Mon, 30 Mar 2026 00:00:00 +0530 Wed, 01 Apr 2026 07:51:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788976 Rectification under section 154 cannot be used to reargue a concluded claim against surcharge and education cess on income taxed under the India-USA tax treaty. A request that seeks reconsideration of the merits, rather than correction of a mistake apparent from the record, falls outside rectification jurisdiction. The text notes that the earlier appellate view had already rejected the treaty-based challenge and that the applicable precedent was against the assessee. On that basis, the rejection of the rectification application was upheld and the challenge to the levy failed. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788976