Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale

1 SCR 890Reported decision1960#6216 most cited

What is Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale authority for?

An error is not considered 'apparent from the record' for rectification purposes if it requires a lengthy process of reasoning or involves debatable points where multiple opinions are possible. A decision on a debatable point of law does not constitute a mistake apparent from the record.

18

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2008 to 2026.

Also referred to as

Satyanarayan Laxminarayan Hegde · Mallikarjun Bhavanappa Tirumale · mistake apparent from record · section 154 · debatable point of law · rectification u/s 154 · long drawn process of reasoning

Sections most often in play

Section 143(3)Section 154Section 139(1)Section 115JBSection 144C(1)Section 153ASection 153CSection 234A

Issues it is cited on

section 17(1)mistake apparent from recordrectification u/s 154section 17income-tax officersection 154section 15section 139(1)section 271section 115section 139section 27

Judgments citing Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale

DY. COMMISSIONER OF INCOME TAX CIRCLE-1(1) , PUNE vs. FIAT INDIA AUTOMOBILES PRIVATE LIMITED, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 1098/PUN/2025[2014-15]Status: DisposedITAT Pune08 Jan 2026AY 2014-15

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Percy PardiwallaFor Respondent: Shri Amol Khairnar
Section 115JSection 143(3)Section 154

…arlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Sathyanarayan Laxminarayan Hegde v. Mallikarjun Bhavanappa Tirumale [1960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

M/S. FIAT INDIA AUTOMOBILES PRIVATE LIMITED,PUNE vs. ACIT CIRCLE 1(1), PUNE

In the result, the appeal filed by the assessee in ITA

ITA 1027/PUN/2025[2014-15]Status: DisposedITAT Pune08 Jan 2026AY 2014-15

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Percy PardiwallaFor Respondent: Shri Amol Khairnar
Section 115JSection 143(3)Section 154

…arlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Sathyanarayan Laxminarayan Hegde v. Mallikarjun Bhavanappa Tirumale [1960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

RAVI RAMBABU,HYDERABAD vs. ACIT., CENTRAL CIRCLE 2(3), HYDERABAD

ITA 651/HYD/2025[2020-21]Status: DisposedITAT Hyderabad26 Nov 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 651/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Ravi Rambabu, Vs. Assistant Commissioner Hyderabad. Of Income Tax, Circle-2(3), Pan: Abspr3702P Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Rectification Order Dated 28.03.2025 Passed By The Cit (Appeals) Under Section 154 Of The Income-Tax Act, 1961 (For Short, “Act"), Dated 28.03.2025, Which In Turn Arises From The Order Passed By The Cit(A) Disposing Of The Assessee’S Appeal, Vide His Order Dated 29.01.2025. The Assessee Has Assailed The Impugned Order Passed By The Cit(A)

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 115BSection 139(1)Section 143(3)Section 153ASection 153BSection 153CSection 154Section 68Section 69Section 69A

…earlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale [I960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

MCM DEVELOPERS,AURANGABAD vs. DCIT. CENTRAL CIRCLE-1, AURANGABAD, AURANGABAD

In the result, the appeal filed by the assessee is allowed

ITA 362/PUN/2025[2018-2019]Status: DisposedITAT Pune17 Sept 2025AY 2018-2019

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Pramod ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 153ASection 153CSection 154Section 269SSection 270ASection 271DSection 40A(3)

…earlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale [I960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of 14 reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of…

IMPERIAL HOUSING, PUNE,PUNE vs. ITO, WARD-2(2), PUNE, PUNE

In the result, the appeal filed by the Revenue as well as the appeal filed by the assessee are dismissed

ITA 1792/PUN/2024[2015-16]Status: DisposedITAT Pune25 Oct 2024AY 2015-16

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2015-16

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 143(3)Section 154Section 154(1)Section 35D

…cer to go into the true scope of the relevant provisions of the Act in a proceeding under section 154 of the Income-tax Act, 1961. A mistake apparent on the record must be an obvious and patent mistake and not something which can be Bhavanappa Tirumale [1950] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

INCOME TAX OFFICER, WARD-2(2), PUNE, PUNE vs. IMPERIAL HOUSING, PUNE

In the result, the appeal filed by the Revenue as well as the appeal filed by the assessee are dismissed

ITA 1120/PUN/2023[2015-16]Status: DisposedITAT Pune25 Oct 2024AY 2015-16

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2015-16

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 143(3)Section 154Section 154(1)Section 35D

…cer to go into the true scope of the relevant provisions of the Act in a proceeding under section 154 of the Income-tax Act, 1961. A mistake apparent on the record must be an obvious and patent mistake and not something which can be Bhavanappa Tirumale [1950] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

FIRST INTERNATIONAL BUSINESS LTD.,JALANDHAR vs. INCOME TAX OFFICER, JALANDHAR

In the result, the appeal of the assessee ITA No

ITA 46/ASR/2023[2012-13]Status: HeardITAT Amritsar20 Sept 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.46/Asr/2023 Assessment Year: 2012-13

Section 143(3)Section 154Section 154oSection 194CSection 250Section 40

…earlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Sathyanarayan Laxminarayan Hegde v. Mallikarjun BhavanappaTirumale [1960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD vs. SRINIVASA CHAKRAVARTHI RAJU GOKARAJU, HYDERABAD

The appeal of the Revenue is allowed

ITA 2114/HYD/2018[2010-11]Status: DisposedITAT Hyderabad21 Jun 2023AY 2010-11

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Pawan Kumar Chakrapani, ARFor Respondent: Shri K. Madhusudan, CIT-DR
Section 143(3)Section 154Section 249(4)

…earlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale [I960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

COMMISSIONER OF INCOME TAX (TDS) vs. M/S VODAFONE IDEA LIMITED

ITA/47/2020HC Orissa02 Jan 2023

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

For Respondent: ASSTT.S.G.I., SC, F.T,SC, ECI,SC, NRC

…Page No.# 1/16 GAHC010056742020 2025:GAU-AS:14238 THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH) Case No. : Review.Pet./47/2020 AMINUR ALI @ AMINOOR ISLAM S/O LT. KHUDU SHEIKH, R/O VILL- CHOT BHASHSJANI P.O. CHAGAL CHARA, P.S. AND DIST. DHUBRI, ASSAM, PIN 783324 VERSUS THE UNION OF INDIA AND 7 ORS REPRESENTED BY THE SECRETARY TO THE MINISTRY OF HOME AFFAIRS, GOVT. OF INDIA, MINISTRY OF HOME AFFAIRS, SHASTRI BHAWAN, TILAK MARG, NEW DELHI-1. 2:THE STATE OF ASSAM REPRESENTED BY THE SECRETARY TO THE GOVT. OF ASSAM DEPART…

PRINCIPAL COMMISSIONER OF INCOME TAX-I vs. M/S MAHLA REAL ESTATE PVT. LTD.

ITA/47/2020HC Rajasthan09 Nov 2021

Bench: AKIL KURESHI,REKHA BORANA

For Respondent: ASSTT.S.G.I., SC, F.T,SC, ECI,SC, NRC

…Page No.# 1/16 GAHC010056742020 2025:GAU-AS:14238 THE GAUHATI HIGH COURT (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH) Case No. : Review.Pet./47/2020 AMINUR ALI @ AMINOOR ISLAM S/O LT. KHUDU SHEIKH, R/O VILL- CHOT BHASHSJANI P.O. CHAGAL CHARA, P.S. AND DIST. DHUBRI, ASSAM, PIN 783324 VERSUS THE UNION OF INDIA AND 7 ORS REPRESENTED BY THE SECRETARY TO THE MINISTRY OF HOME AFFAIRS, GOVT. OF INDIA, MINISTRY OF HOME AFFAIRS, SHASTRI BHAWAN, TILAK MARG, NEW DELHI-1. 2:THE STATE OF ASSAM REPRESENTED BY THE SECRETARY TO THE GOVT. OF ASSAM DEPART…

DCIT LTU 2, MUMBAI vs. TATA MOTORS LTD, MUMBAI

In the result, appeal filed by the revenue for assessment year 2007-08

ITA 4219/MUM/2018[2007-08]Status: DisposedITAT Mumbai18 Feb 2020AY 2007-08

Bench: Shri M. Balaganesh (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2007-08 The Dcit (Ltu)-2, M/S Tata Motors Ltd., World Trade Centre, Bombay House, 24, Homi Mody Centre No. 1, 29Th Floor, Street, Hutatma Chowk, Cuffe Parade, Vs. Mumbai - 400001 Mumbai - 400005 Pan : Aaact2727Q (Appellant) (Respondent) Revenue By : Shri R. Manjunatha Swamy (Cit) Assessee By : Shri Rajan Vora & Nikhil Tiwari (Ars)

For Appellant: Shri Rajan Vora & Nikhil Tiwari (ARs)For Respondent: Shri R. Manjunatha Swamy (CIT)
Section 115JSection 143Section 143(3)Section 154Section 263

…n earner, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyananrayn Laxminarayan Hedge v. MallikarjunBhavanappa Tirumale (1960) 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the fact of the record. A decision on a debatable point of la…

M/S KIRAN INFRA ENGINEERS LTD. RACHANA (JV),JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 4, JAIPUR

In the result, these three appeals of the assessee are allowed

ITA 570/JPR/2018[2014-15]Status: DisposedITAT Jaipur05 Aug 2019AY 2014-15
For Appellant: Shri Manish Agrawal (C.A.)For Respondent: Shri Jai Singh (JCIT)
Section 143(3)Section 154Section 80I

…arlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde vs. Mallikarjun Bhavanappa Tirumale (1960) 1 SCR 890, this Court while spelling out the scope of the power of a High Court under Art. 226 of the Constitution ruled that an error which has to be established by a long-drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on debatable point of law is…

M/S KIRAN INFRA ENGINEERS LTD. RACHANA (JV),JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 4, JAIPUR

In the result, these three appeals of the assessee are allowed

ITA 569/JPR/2018[2013-14]Status: DisposedITAT Jaipur05 Aug 2019AY 2013-14
For Appellant: Shri Manish Agrawal (C.A.)For Respondent: Shri Jai Singh (JCIT)
Section 143(3)Section 154Section 80I

…arlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde vs. Mallikarjun Bhavanappa Tirumale (1960) 1 SCR 890, this Court while spelling out the scope of the power of a High Court under Art. 226 of the Constitution ruled that an error which has to be established by a long-drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on debatable point of law is…

M/S KIRAN INFRA ENGINEERS LTD. RACHANA (JV),JAIPUR vs. INCOME TAX OFFICER, WARD-4-2, JAIPUR

In the result, these three appeals of the assessee are allowed

ITA 568/JPR/2018[2012-13]Status: DisposedITAT Jaipur05 Aug 2019AY 2012-13
For Appellant: Shri Manish Agrawal (C.A.)For Respondent: Shri Jai Singh (JCIT)
Section 143(3)Section 154Section 80I

…arlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde vs. Mallikarjun Bhavanappa Tirumale (1960) 1 SCR 890, this Court while spelling out the scope of the power of a High Court under Art. 226 of the Constitution ruled that an error which has to be established by a long-drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on debatable point of law is…

M/S. KOTHARI & BROTHERS, ,HUBBALLI vs. INCOME TAX OFFICER, WARD-2(2), HUBBALLI

In the result, the assessee’s appeal for Assessment Year 2012-13 is allowed

ITA 2637/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2018AY 2012-13

Bench: Shri Jason P Boaz & Shri Laliet Kumarassessment Year : 2012-13 M/S. Kothari & Brothers, Vs. The Income Tax Officer, Broadway, Ward – 2(2), Hubli. Hubli. Pan : Aadfk 4824 B Appellant Respondent Assessee By : Shri. Ravishankar, Advocate Revenue By : Shri. Siddappaji R. N, Addl. Cit Date Of Hearing : 04.10.2018 Date Of Pronouncement : 14.11.2018 O R D E R

For Appellant: Shri. Ravishankar, AdvocateFor Respondent: Shri. Siddappaji R. N, Addl. CIT
Section 133ASection 143(3)Section 154

…the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde and ors. v. Millikarjun Bhavanappa Tirumale [1960] 1 SCR 890, this Court while spelling out the scope of the power of a High Court under Article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

JCIT, BANGALORE vs. M/S BHUWALKA PIPES PVT. LTD.,, BANGALORE

In the result, the appeal filed by the revenue is allowed

ITA 882/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jan 2018AY 2011-12

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raojoint Commissioner Of Income-Tax (Osd), Circle 1(1)(2), Bengaluru. … Appellant Vs. M/S.Bhuwalka Pipes Pvt. Ltd. ‘Solus’, 8Th Floor, E & G, No.2 1St Cross Road, Jc Road, Bengaluru-560027. … Respondent Pan: Aabcb 7778 E

For Appellant: Shri P.Dinesha, AdvocateFor Respondent: Dr.Pradeep Kumar, Addl.CIT(DR)
Section 143(3)Section 14ASection 154Section 37

…earlier, the High Court of Bombay opined that the original assessments were in accordance with law though in our opinion the High Court was not justified in going into that question. In Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale [I960] 1 SCR 890, this court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of la…

ITO, CHENNAI vs. ALCHEMY BIOTECH PVT LTD., CHENNAI

In the result the appeal of the Revenue and the Cross

ITA 1165/CHNY/2016[2007-08]Status: DisposedITAT Chennai01 May 2017AY 2007-08

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri N. Devanathan, AdvocateFor Respondent: 06.04.2017
Section 250(6)Section 253(2)

…record must be an obvious and patent mistake and not something which can be established by a long drawn process of reasoning on points on which there may conceivably be two opinions. In Satyanarayan Laxminarayan Hegde v. Mallikaljun Bhavanappa Tirumale [19601 1 SCR 890, the court while spelling out the scope of the power of a High Court under article 226 of the Constitution ruled that an error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions cannot be said to be an error apparent on the face of the record. A decision on a debatable point of law…

ASSISTANT COMMNR., INCOME TAX, RAJKOT vs. SAURASHTRA KUTCH STOCK EXCHANGE LTD

C.A. No.-001171-001171 - 2004Supreme Court15 Sept 2008
Section 11Section 12ASection 143Section 154Section 25Section 254

…el on either side were unable to suggest any clear-cut rule by which the boundary between the two classes of errors could be demarcated”. (emphasis supplied) 33. In Satyanarayan Laxminarayan Hegde & Ors. v. Mallikarjun Bhavanappa Tirumale, (1960) 1 SCR 890, this Court referring to Batuk K. Vyas and Hari Vishnu Kamath stated as to what cannot be said to be an error apparent on the face of the record. 2 34. The Court observed; “An error which has to be established by a long drawn process of reasoning on points where there may conceivably be two opinions can hardly be said to be…

Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale (1 SCR 890) — Cited in 18 Judgments | BharatTax