Master Construction Co. (P) Ltd. v. State of Orissa

17 STC 360Reported decision1966#11458 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2014 to 2025.

Sections most often in play

Section 116 Section 139(5)Section 143(1)Section 154 Section 155 Section 156 Section 186 Section 195

Issues it is cited on

section 186 section 116 rectification under section 154 retrospective amendment section 155 mistake apparent from record section 254(2)section 206c section 206 section 18 section 139(5)section 9(1)(vi)

Judgments citing Master Construction Co. (P) Ltd. v. State of Orissa

TRANS UNION LLC,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX 4(1)(2), MUMBAI

ITA 1441/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Jul 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(1)Section 154Section 250Section 9(1)(vi)

…to clerical or arithmetical mistake. On the other hand, it does not cover any mistake which may be discovered by a complicated process of investigation, argument or proof. As observed by this Court in Master Construction Co. (P) Ltd. v. State of Orissa [1966] 17 STC 360, an error which is apparent from record should be one which is not an error which depends for its discovery on elaborate arguments on questions of fact or law. 11. "Mistake" is an ordinary word but in taxation laws, it has a special significance. It is not an arithmetical error which, after a judicious probe into the record from which it is suppos…

TRANS UNION LLC,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX 4(1)(2), MUMBAI

ITA 1405/MUM/2025[2018-19]Status: DisposedITAT Mumbai17 Jul 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(1)Section 154Section 250Section 9(1)(vi)

TRANS UNION LLC,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX 4(1)(2), MUMBAI

ITA 1404/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Jul 2025AY 2017-18

Section 143(1)Section 154Section 250Section 9(1)(vi)

…clerical or arithmetical mistake. On the other\nhand, it does not cover any mistake which may be discovered by a\ncomplicated process of investigation, argument or proof. As observed by this Court in Master\nConstruction Co. (P) Ltd. v. State of Orissa [1966] 17 STC 360, an error which\nis apparent from record should be one which is not an error which depends for\nits discovery on elaborate arguments on questions of fact or law.\n\n11.\n\"Mistake\" is an ordinary word but in taxation laws, it has a special\nsignificance. It is not an arithmetical error which, after a judicious probe into the\nrecord from which it…

TRANS UNION LLC,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX 4(1)(2), MUMBAI

ITA 1403/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Jul 2025AY 2016-17

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(1)Section 154Section 250Section 9(1)(vi)

…clerical or arithmetical mistake. On the other\nhand, it does not cover any mistake which may be discovered by a complicated\nprocess of investigation, argument or proof. As observed by this Court in Master\nConstruction Co. (P) Ltd. v. State of Orissa [1966] 17 STC 360, an error which\nis apparent from record should be one which is not an error which depends for\nits discovery on elaborate arguments on questions of fact or law.\n\n11.\n\"Mistake\" is an ordinary word but in taxation laws, it has a special\nsignificance. It is not an arithmetical error which, after a judicious probe into the\nrecord from which it…

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

ITA 2486/MUM/2017[2007-08]Status: DisposedITAT Mumbai07 Jul 2023AY 2007-08

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

Section 14ASection 154Section 199(2)Section 80I

…erical or arithmetical mistakes. On the other hand, it does not cover any mistake which may be discovered by a complicated process of investigation, argument or proof. As observed by the Apex Court in Master Construction Co. (P) Ltd. v. State of Orissa [1966] 17 STC 360, an error which is apparent from record should be one which is not an error which depends for its discovery on elaborate arguments on questions of fact or law... See T.S. Balaram ITO v. Volkart Bros. [1971] 82 ITR 50 (SC) Mistake' is an ordinary word but in taxation laws, it has a special Page No. 61 ITA NO. 2485 & 2486/MUM/2017 C.O. NO. 265 & 35…

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

ITA 2485/MUM/2017[2006-07]Status: DisposedITAT Mumbai07 Jul 2023AY 2006-07

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

Section 14ASection 154Section 199(2)Section 80I

BEED TALUKA DHUD VASAYIK SAHAKARI SANGH LTD,,BEED vs. INCOME-TAX OFFICER,, BEED

In the result, the appeal of assessee is allowed

ITA 1025/PUN/2017[2010-11]Status: DisposedITAT Pune01 Aug 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: NoneFor Respondent: Shri Prashant Gudekar

Section 143(3)Section 154Section 80Section 80PSection 80P(2)(b)Section 80P(2)(c)

…rical or arithmetical mistakes. On the other hand, it does not cover any mistake which may be discovered by a complicated process of investigation, argument or proof. As observed by the apex court in Master Construction Co. (P.) Ltd. v. State of Orissa [1966] 17 STC 360, an error which is apparent from the record should be one which is not an error which depends for its discovery on elaborate arguments on questions of fact or law. A similar view was also expressed in Satyanarayan Laxminarayan Hegde v. Mallikarjun Bhavanappa Tirumale [1960] AIR 1960 SC 137. It is to be noted that the language used in Order 47, ru…

KIRIT R. PATEL,MUMBAI vs. ITO WD 21(1)(2), MUMBAI

In the result, appeal filed by the assessee is allowed

ITA 6717/MUM/2010[2007-08]Status: DisposedITAT Mumbai10 Feb 2016AY 2007-08

Bench: Shri B.R.Baskaran & Shri Pawan Singhassessment Year: 2007-08 Shri Kirit R. Patel, Ito Ward 21(1)(2) 5Th Floor, Ram Niwas, 34 C-10 Building, Pratyakshkar Bhavan, Vallabhnagar, N.S. Road, Bandra-Kurla Complex, Bandra (E), Vs. Jvpd, Vile Parle (W), Mumbai-400051 Mumbai-400057 Pan: Aabpp3139J (Appellant) (Respondent)

For Appellant: Shri Rashmikant ChokseyFor Respondent: Shri Sachchidanand Dube (DR)

Section 143(3)Section 154

…pinions cannot be said to be an error apparent on the face of the record. A decision on debatable point of law is not a mistake apparent from the record.......” 6. Further, the Hon’ble Apex Court in Master Construction Co. (P.) Ltd. v. State of Orissa [(1966) 17 STC 360, 363], expressed the view that an error which is apparent on the fact 3 ITA No. 6717/M/2010 Shri Kirit R. Patel of the record should be one which is not an error which depends for its discovery on elaborate arguments on questions of fact or law. 7. Further, the Hon’ble Apex Court in Satynarayan Laxminarayan Hedge vs. Mallikarjun Bhavanappa Thir…

JRD STOCK BROKERS (P) LTD vs. COMMISSIONER OF INCOME TAX-II

ITA/1/2014HC Delhi22 Aug 2014

Section 132

…arithmetical mistakes. On the other hand, it does not cover any mistake which may be discovered by a complicated process of investigation, argument or proof. As observed by the Supreme Court in Master Construction Co. (P) Ltd. vs. State of Orissa [1996] 17 STC 360, an error which is apparent on the face of the record should be one which is not an error which depends for its discovery on elaborate arguments on questions of fact or law. A similar view was also expressed in Satyanarayan Laxinarayan Hege vs. Mallikarjun Bhavanappa Tirumale AIR 1960 SC137. It is to be noted that the language used in Order…