TaxTMI 
TaxTMI 
1982 (2) TMI 87
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....ppeals by the assessee against the orders of the AAC holding that the ITO was justified in rejecting the assessees' applications under Section 154. The assessees are HUFS. They are partners in the firm of D. Chunnilal Dahyabhai & Shah, represented by their kartas. While submitting the return for the assessment year 1975-76, the firm added a note in the statement of accounts accompanying it as foll....
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....under section 143(1) taking the share income of the kartas as determined in the firm's case. The assessee applied for rectification of their assessments requesting that salary from the firm should be deleted as the same has been included in the individual assessments. This was negatived by the ITO. The AAC agreed with the ITO on the ground that there was no mistake apparent from records. The asses....
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....resentative argued that there were no mistakes apparent from record. The assessees were partners in the firm. Their share income had to be determined in the assessment of the firm. The salary had been included in the hands of the partners. The share thus determined had to be transported without any modification to the assessments of the partners. What the assessees were urging was a reconsideratio....
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....assessment of the firm. The principle stated in Mahendra Mills' case would apply to the present case also. In that case a change in the value of the closing stock for one year was considered to be a mistake apparent from record justifying the rectification of the value of the opening stock for another year. If the revenue's interpretation is correct, one could say that the mistake should be appare....