Sidhramappa AndannappaManvi v. Commissioner of Income-tax

21 ITR 333High Court1952#5461 most cited

What is Sidhramappa AndannappaManvi v. Commissioner of Income-tax authority for?

A debatable point of law or a complex process of reasoning, where two opinions are conceivable, does not constitute a mistake apparent from the record that can be rectified under Section 154 of the Income-tax Act, 1961.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2015 to 2026.

Also referred to as

Sidhramappa Andannappa Manvi · Section 154 · mistake apparent from record · error apparent on face of record · debatable point of law · Income-tax Act 1961 · rectification

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)rectification u/s 154mistake apparent from recordsection 17section 194cincome-tax officersection 154section 115jbsection 19section 139(1)section 153cscrutiny assessment

Judgments citing Sidhramappa AndannappaManvi v. Commissioner of Income-tax

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

…re 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 is not a mistake apparent from the record - see Sidhramappa Andannappa Manvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.) The power of the officers mentioned in Section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case, it is not necessary for us to spell out the distinctio…

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

…re 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 is not a mistake apparent from the record - see Sidhramappa Andannappa Manvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.) The power of the officers mentioned in Section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case, it is not necessary for us to spell out the distinctio…

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

…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 is not a mistake apparent from the record—see Sidhramappa AndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

Mcm Developers, Aurangabad vs. DCIT. Central Circle-1, 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)

…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 is not a mistake apparent from the record—see Sidhramappa AndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

Imperial Housing, Pune vs. ITO, Ward-2(2), 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

…re 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 is not a mistake apparent from the record - see Sidhramappa Andannappa Manvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom) The power of the officers mentioned in Section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record In this case, it is not necessary for us to spell out the distinction b…

Income Tax Officer, Ward-2(2), 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

…re 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 is not a mistake apparent from the record - see Sidhramappa Andannappa Manvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom) The power of the officers mentioned in Section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record In this case, it is not necessary for us to spell out the distinction b…

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

…here 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 is not a mistake apparent from the record - see SidhramappaAndannappa Manvi v. Commissioner of Income-tax[1952] 21 ITR 333 (Bom.) The power of the officers mentioned in Section154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case, it is not necessary for us to spell out the distinction…

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

…NO. 2485 & 2486/MUM/2017 C.O. NO. 265 & 355/MUM/2018 M/s. Patel Engineering Ltd. opinion.................... A decision on a debatable point of law is not a mistake apparent from the record-see SidhramappaAndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

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

…NO. 2485 & 2486/MUM/2017 C.O. NO. 265 & 355/MUM/2018 M/s. Patel Engineering Ltd. opinion.................... A decision on a debatable point of law is not a mistake apparent from the record-see SidhramappaAndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

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)

…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 is not a mistake apparent from the record—see Sidhramappa AndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income- Page 7 of 12 tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out…

Vinodkumar S Totla, Ahmedabad vs. ITO, Ward-7(1)(4), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 11/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad08 Apr 2022AY 2011-12
For Appellant: Shri S.N. Divetia, A.RFor Respondent: Shri R.R. Makwana, Sr. D.R
Section 1Section 154Section 250Section 26Section 54Section 54F

…kumar S. Totla vs. ITO Girdhari Lal & Co. 187 ITR 257 (Allahabad), the Allahabad High Court Section 154 does not give power to the ITO to change his opinion and review his order. The Bombay High Court in the case of Sidhramappa andannappa Manvi v. CIT [1952] 21 ITR 333 (Bombay) held that the power of the Tribunal to rectify the mistake is undoubtedly a limited power; it is not a power of revision or review, but it is limited to correcting only those mistakes which are apparent on the record. A mistake must be patent on the record; it must not be a mistake which can be discovered by a process of elucidation, or a…

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

…ere 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 law is not a mistake apparent from the record.- See SidhramappaAndannappaMani v. Commissioner of Income Tax ( 1952) 21 ITR 333 (Bom). The power of the officers mentioned in section 154 of the Income Tax Act, 1961, to correct “any mistake apparent from the record” is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an “error apparent on the face of the record.” In this case it is not necessary for us to spell out the distinction…

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

…f 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 not a mistake apparent from the record [see Sidhramappa Andannappa Manvi vs. CIT (1952) 21 ITR 333 (Bom) : TC 8R.1234]. The power of the officers mentioned in s. 154 of the IT Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

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

…f 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 not a mistake apparent from the record [see Sidhramappa Andannappa Manvi vs. CIT (1952) 21 ITR 333 (Bom) : TC 8R.1234]. The power of the officers mentioned in s. 154 of the IT Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

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

…f 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 not a mistake apparent from the record [see Sidhramappa Andannappa Manvi vs. CIT (1952) 21 ITR 333 (Bom) : TC 8R.1234]. The power of the officers mentioned in s. 154 of the IT Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record." In this case it is not necessary for us to spell out the distinctio…

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

…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 is not a mistake apparent from the record—see Sidhramappa AndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in Section 154 of the Income Tax Act, 1961 to correct “any mistake apparent from the record” is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an “error apparent on the face of the record”. In this case it is not necessary for us to spell out the distinction…

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

…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 is not a mistake apparent from the record—see Sidhramappa AndannappaManvi v. Commissioner of Income-tax [1952] 21 ITR 333 (Bom.). The power of the officers mentioned in section 154 of the Income-tax Act, 1961, to correct "any mistake apparent from the record" is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an "error apparent on the face of the record.". . . . ” In the present case, the assessee-company had not pointed…

ACIT 11(1), Mumbai vs. Fun Multiplex P.Ltd, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 6731/MUM/2014[2008-09]Status: DisposedITAT Mumbai09 Sept 2016AY 2008-09

Bench: Shri Amit Shukla & Shri Ashwani Tanejaassessment Year: 2008-09 Acit-11(1) M/S. Fun Multiplex Pvt. Room No.439, Ltd. बनाम/ Aayakar Bhavan, 844/4, Shah Industrial Vs. M.K. Marg, Estate, Off New Link Road, Mumbai-20 Opp. Laxmi Industrial Estate, Andheri(W), Mumbai-400053 (Revenue) (Respondent ) P.A. No.Aaace8924E Revenue By Shri Asghar Zain (Dr) Respondent By Shri Jay B. Bhansali & Hitendra Bhandari (Dr)

Section 143(3)Section 154Section 43(1)

…rawn 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 is not a mistake apparent from the record-see Sidhrarrappa v. CIT, Bombay (21 ITR 333). The power of the officers mentioned in section 154 of the Income-tax Act, 1961 to correct any mistake apparent from the record is undoubtedly not more than that of the High Court to entertain a writ petition on the basis of an 'error apparent on the face of the record. In this case it is not necessary for us to spell out the distinction between…

Grishma Securities P.Ltd, Mumbai vs. ITO 4(1)(2), Mumbai

ITA 7130/MUM/2014[2006-07]Status: DisposedITAT Mumbai26 Aug 2016AY 2006-07
For Appellant: Shri Anuj Kishnadwala-ARFor Respondent: Shri K.V. Vispute-DR
Section 143(3)Section 154Section 254(1)

…आयकर अपीलीय अिधकरण, मुंबई “ जी जी जी” खंडपीठ जी Income-tax Appellate Tribunal -“G”Bench Mumbai सव"ी सव"ी सव"ी राजे"" सव"ी राजे"" राजे"",लेखा राजे"" लेखा लेखा सद"य लेखा सद"य सद"य एवं सद"य एवं एवं, राम लाल नेगी एवं राम लाल नेगी राम लाल नेगी, "याियक राम लाल नेगी "याियक "याियक सद"य "याियक सद"य सद"य सद"य Before S/Shri Rajendra,Accountant Member and Ram Lal Negi,Judicial Member आयकर आयकर अपील अपील संसंसंसं./ITA/7130/Mum/2014,िनधा"रण िनधा"रण वष" वष" /Assessment Years: 2006-07 आयकर आयकर अपील अपील िनधा"रण िनधा"रण वष" वष" Grishma Securities Pvt.Ltd. ITO- 4(1)(2) 620,P J Tower,Dalal Street, Mumbai. Vs. Fort,Mumbai-400 0…

Aristo Pharmaceuticals P.Ltd, Mumbai vs. Addl CIT 2(1), Mumbai

In the result, both the appeals filed by the assessee are hereby allowed

ITA 6679/MUM/2012[2008-09]Status: DisposedITAT Mumbai06 Nov 2015AY 2008-09

Bench: Shri G.S. Pannu & Shri Sanjay Garg

For Appellant: Shri Ajay Kumar Rastogi, A.RFor Respondent: Shri Sanjay Singh, CIT DR
Section 115Section 115WSection 154

…on 154 of the Income Tax Act. Reliance in this respect can be placed on the decisions of the Hon’ble Supreme Court in the case of “T.S. Balaram ITO vs. Volkat Brothers” and of the Hon’ble Bombay High Court in the case of “Sidhramappa Andannappa Manvi vs. CIT” 21 ITR 333. 7. In view of the above, the enhancement of assessable fringe benefits by the AO in the garb of rectification of original assessment order cannot be held to be justified and the same is accordingly set aside. ITA No.6679/M/2012 for A.Y. 2008-09 8. Since the facts and issues involved in this appeal are identical to the appeal of the assessee i.e.…

Sidhramappa AndannappaManvi v. Commissioner of Income-tax (21 ITR 333) — Cited in 21 Judgments | BharatTax