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Rectification of loss set-off with shareholding change u/s 154 is debatable, not a mistake on record.

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....Rectification of mistake u/s 154 - it can be safely concluded that set-off of losses when there is a change in shareholding is not a mistake apparent from record, and is debatable issue in the facts and circumstances discussed supra and it is not a case rectification - AT....

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Rectification of loss set-off with shareholding change u/s 154 is debatable, not a mistake on record.