Prakashbhai Manchharam Mistry, Surat vs. Income Tax Officer, Ward 3(2)(1), Surat
In the result, appeal of the assessee is dismissed
ITA 132/SRT/2025[2012-13]Status: DisposedITAT Surat04 Nov 2025AY 2012-13
Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.132/Srt/2025 Assessment Year: (2012-13) (Hybrid Hearing) Prakash Manchharam Mistry, Vs. The Ito, 57, Viramnagar Society, Dabholi, Ward – 3(2)(1), Surat - 395004 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aqtpm1279Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Ketan Jagirdar, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 07/08/2025 Date Of Pronouncement 04/11/2025
Section 142(1)Section 144Section 148Section 154Section 250Section 50C
…opinions. The Hon’ble Supreme Court in case of CIT vs. Hero Cycles Pvt. Ltd., 228 ITR 463 (SC) held that a point which was not examined on fact or in law cannot be dealt as mistake apparent on the record. Similarly, in case of CIT vs. Keshri Metals Pvt. Ltd., 237 ITR 165 (SC), it was held that reference to documents outside the records and the law is impermissible when applying the provisions of section 154 of the Act. We find that the rectification sought by the appellant, except the double addition of Rs.22,10,884/- u/s 50C of the Act, were not mistakes apparent from record but pertain to facts and questions of…