https://www.taxtmi.com/caselaws?id=60685 The character of an amount shown as "reserve against export obligation" required examination of its true nature and purpose under the Companies Act, 1956, and could not be resolved by a mechanical reading of the record. Because the reserve-versus-provision distinction depended on surrounding facts, intention, and governing case law, the question was debatable rather than an obvious patent error. Rectification under section 13 of the Companies (Profits) Surtax Act, 1964 is confined to mistakes apparent from the record, so such a contested issue fell outside its scope. The rectification order was therefore invalid and the assessee succeeded on the jurisdictional point. en-us Fri, 12 Aug 1983 00:00:00 +0530 Fri, 07 Jan 2011 16:06:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60685 The character of an amount shown as "reserve against export obligation" required examination of its true nature and purpose under the Companies Act, 1956, and could not be resolved by a mechanical reading of the record. Because the reserve-versus-provision distinction depended on surrounding facts, intention, and governing case law, the question was debatable rather than an obvious patent error. Rectification under section 13 of the Companies (Profits) Surtax Act, 1964 is confined to mistakes apparent from the record, so such a contested issue fell outside its scope. The rectification order was therefore invalid and the assessee succeeded on the jurisdictional point. Case-Laws Income Tax Fri, 12 Aug 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60685