Rectification u/s 154 without careful consideration of the facts and circumstances of the case, and the basic issue whether section 154 could be invoked at all

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....d by the Revenue Audit as well as Internal Audit, sufficient care is not sometimes taken. In most of the cases the assessments are being rectified u/s 154 of I.T. Act, 1961, without careful consideration of the facts and circumstances of the case, and the basic issue whether section 154 could be invoked at all. Section 154 can be invoked only for rectifying mistakes "apparent from the record" Law ....

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....here are conflicting High Court decisions on the issue whether information derived from the scrutiny note of the Audit is sufficient information to uphold action u/s. 147(b), and the matter is before the Supreme Court for final adjudication. 3. A safe remedy in cases where the assessments have not been subjected to appeal is intervention by the CIT under section 263, if there is time available fo....