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    <title>2026 (5) TMI 296 - ITAT DELHI</title>
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    <description>Rectification under section 154 was not available where the proposed disallowance of interest expenditure depended on whether tax was required to be deducted or deposited at source, because that issue was not a patent error apparent from the record. The allowability of the expenditure and the effect of the alleged TDS default required examination and interpretation, making the matter at least debatable and outside the limited rectification power. As the original assessment had accepted the claim, the statutory conditions for section 154 were not met, and the deletion of the addition was sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791094</link>
      <description>Rectification under section 154 was not available where the proposed disallowance of interest expenditure depended on whether tax was required to be deducted or deposited at source, because that issue was not a patent error apparent from the record. The allowability of the expenditure and the effect of the alleged TDS default required examination and interpretation, making the matter at least debatable and outside the limited rectification power. As the original assessment had accepted the claim, the statutory conditions for section 154 were not met, and the deletion of the addition was sustained.</description>
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      <pubDate>Wed, 25 Mar 2026 00:00:00 +0530</pubDate>
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