https://www.taxtmi.com/caselaws?id=793647 A disallowance under section 40(a)(ia) for alleged non-deduction of tax at source on interest payments could not be sustained through rectification under section 154 because the point was debatable and required detailed enquiry, not a mistake apparent from the record. Where the assessment had already been completed under section 143(3), the limited rectification power could not be used to decide such a controversy. The rectification was therefore not sustainable, and the disallowance could not be upheld in section 154 proceedings. en-us Fri, 05 Jun 2026 00:00:00 +0530 Sat, 20 Jun 2026 08:04:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793647 A disallowance under section 40(a)(ia) for alleged non-deduction of tax at source on interest payments could not be sustained through rectification under section 154 because the point was debatable and required detailed enquiry, not a mistake apparent from the record. Where the assessment had already been completed under section 143(3), the limited rectification power could not be used to decide such a controversy. The rectification was therefore not sustainable, and the disallowance could not be upheld in section 154 proceedings. Case-Laws Income Tax Fri, 05 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793647