https://www.taxtmi.com/caselaws?id=798743 Diminution in the value of investment in a wholly owned subsidiary made to expand and strengthen existing business operations may qualify as a business loss where binding jurisdictional precedent supports that treatment. An intimation issued under section 143(1)(a) performs a quasi-judicial function and cannot disregard such precedent solely because the tax audit report characterises the expenditure as capital. Failure to consider a jurisdictional High Court decision already in force when the intimation was issued constitutes a mistake apparent from the record. Rectification under section 154 was therefore maintainable, and the disallowance was liable to be deleted. en-us Tue, 08 Sep 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:13:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798743 Diminution in the value of investment in a wholly owned subsidiary made to expand and strengthen existing business operations may qualify as a business loss where binding jurisdictional precedent supports that treatment. An intimation issued under section 143(1)(a) performs a quasi-judicial function and cannot disregard such precedent solely because the tax audit report characterises the expenditure as capital. Failure to consider a jurisdictional High Court decision already in force when the intimation was issued constitutes a mistake apparent from the record. Rectification under section 154 was therefore maintainable, and the disallowance was liable to be deleted. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798743