https://www.taxtmi.com/caselaws?id=792579 Section 154 cannot be used to materially alter an assessment after immunity under section 270AA has brought the matter to finality; a rectification power is confined to correcting patent mistakes and cannot rewrite assessed loss into taxable income. An estimated disallowance of expenses already recorded in the books does not, by itself, make the expenditure unexplained under section 69C, because that provision applies only where the source of expenditure remains unproved. On that basis, section 115BBE was also inapplicable. The rectification and its affirmation were treated as unsustainable in law. en-us Wed, 27 May 2026 00:00:00 +0530 Sat, 30 May 2026 08:29:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792579 Section 154 cannot be used to materially alter an assessment after immunity under section 270AA has brought the matter to finality; a rectification power is confined to correcting patent mistakes and cannot rewrite assessed loss into taxable income. An estimated disallowance of expenses already recorded in the books does not, by itself, make the expenditure unexplained under section 69C, because that provision applies only where the source of expenditure remains unproved. On that basis, section 115BBE was also inapplicable. The rectification and its affirmation were treated as unsustainable in law. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792579