https://www.taxtmi.com/caselaws?id=57066 Section 154 rectification cannot be used to withdraw exemption on interest from non-resident external account deposits where entitlement depends on residential status under the Foreign Exchange Regulation Act, 1973 and compliance with RBI guidelines, because that issue is not a patent mistake apparent from the record. Where determining the exemption requires enquiry beyond the return and accompanying papers, the proper course is reassessment rather than rectification. The appellate authority may also admit fresh material evidence going to the root of the exemption claim when it is necessary to decide the correct tax liability. On that basis, the rectification orders were held without jurisdiction and the addition made by rectification was quashed. en-us Thu, 03 Feb 2005 00:00:00 +0530 Wed, 15 May 2024 11:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57066 Section 154 rectification cannot be used to withdraw exemption on interest from non-resident external account deposits where entitlement depends on residential status under the Foreign Exchange Regulation Act, 1973 and compliance with RBI guidelines, because that issue is not a patent mistake apparent from the record. Where determining the exemption requires enquiry beyond the return and accompanying papers, the proper course is reassessment rather than rectification. The appellate authority may also admit fresh material evidence going to the root of the exemption claim when it is necessary to decide the correct tax liability. On that basis, the rectification orders were held without jurisdiction and the addition made by rectification was quashed. Case-Laws Income Tax Thu, 03 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57066