https://www.taxtmi.com/caselaws?id=470037 Rectification under Section 254(2) of the Income-tax Act, 1961 is limited to an obvious and patent mistake apparent from the record. It cannot be used to revisit a debatable legal issue on which two reasonable views are possible. The assessment of income from property devolving upon members of a Dayabhaga family raised such a controversy because the members had defined and ascertainable shares and no unity of ownership. A precedent relied upon by the assessee was treated as distinguishable. Accordingly, the alleged legal error did not satisfy the standard for rectification, and the Tribunal's order was not capable of correction under Section 254(2). en-us Tue, 28 Feb 1989 00:00:00 +0530 Tue, 14 Jul 2026 12:05:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470037 Rectification under Section 254(2) of the Income-tax Act, 1961 is limited to an obvious and patent mistake apparent from the record. It cannot be used to revisit a debatable legal issue on which two reasonable views are possible. The assessment of income from property devolving upon members of a Dayabhaga family raised such a controversy because the members had defined and ascertainable shares and no unity of ownership. A precedent relied upon by the assessee was treated as distinguishable. Accordingly, the alleged legal error did not satisfy the standard for rectification, and the Tribunal's order was not capable of correction under Section 254(2). Case-Laws Income Tax Tue, 28 Feb 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470037