Court Clarifies Section 154: Not for Appeals or Disputable Issues, Limited to Explicit Circumstances in Income Tax Act.

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....Rectification u/s 154 - Provision for bad and doubtful debts is under Section 36 (1) (viia) - This Court is of the considered opinion that Section 154 cannot be converted as an appeal for entertaining a ground for adjudication of merits or disputable issues. Thus, the scope of Section 154 is undoubtedly limited with reference to the circumstances narrated under the provision itself. - if at all the petitioner is of an opinion that the Authorities may venture into the adjudication of disputed issues, it is for them to place all the judgments and facts with reference to Section 154 of the Income Tax Act. - HC....