https://www.taxtmi.com/caselaws?id=789493 A debatable question on adjustment of short-term capital gain from depreciable assets against brought-forward business loss cannot be rectified under section 154 because such an issue is not an apparent mistake and requires legal interpretation. The doctrine of diversion of income by overriding title applies only where income never accrues to the assessee; a bank's liquidation arrangement giving DICGC priority over realisations did not amount to diversion at source. A bad debt written off in the books in the course of banking business is deductible once the statutory conditions are met, and actual irrecoverability need not be proved. en-us Tue, 07 Apr 2026 00:00:00 +0530 Wed, 08 Apr 2026 17:02:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789493 A debatable question on adjustment of short-term capital gain from depreciable assets against brought-forward business loss cannot be rectified under section 154 because such an issue is not an apparent mistake and requires legal interpretation. The doctrine of diversion of income by overriding title applies only where income never accrues to the assessee; a bank's liquidation arrangement giving DICGC priority over realisations did not amount to diversion at source. A bad debt written off in the books in the course of banking business is deductible once the statutory conditions are met, and actual irrecoverability need not be proved. Case-Laws Income Tax Tue, 07 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789493