https://www.taxtmi.com/caselaws?id=800393 Foreign tax credit accepted after scrutiny assessment cannot be recomputed through rectification where the proposed restriction requires fresh examination of profit attributable to foreign receipts. Rectification is limited to an obvious and patent error apparent from the record; it does not extend to debatable matters, issues requiring long-drawn inquiry, or a revised view of a claim already examined with supporting particulars. Recomputing the credit in these circumstances constitutes a change of opinion, so the rectification order lacks jurisdiction under Section 154 and must be quashed. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800393 Foreign tax credit accepted after scrutiny assessment cannot be recomputed through rectification where the proposed restriction requires fresh examination of profit attributable to foreign receipts. Rectification is limited to an obvious and patent error apparent from the record; it does not extend to debatable matters, issues requiring long-drawn inquiry, or a revised view of a claim already examined with supporting particulars. Recomputing the credit in these circumstances constitutes a change of opinion, so the rectification order lacks jurisdiction under Section 154 and must be quashed. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800393