(supra), Rama Bai v. CIT

181 ITR 408Supreme Court of India1990#1353 most cited

What is (supra), Rama Bai v. CIT authority for?

Interest received on delayed payment or enhanced compensation awarded under compulsory acquisition is a revenue receipt and is liable to income tax.

84

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2026.

Also referred to as

Rama Bai v. CIT · Rama Bai CIT · interest on compensation · enhanced compensation interest · delayed compensation interest · Section 45(5) Income Tax Act · Section 56(2)(viii) Income Tax Act · revenue receipt · taxability of interest · Land Acquisition Act 1894 · income from other sources · compulsory acquisition interest

Sections most often in play

Section 1961Section 56(2)(viii)Section 10(37)Section 57(iv)Section 145ASection 1894Section 45(5)Section 143(2)

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 45(5)(b)section 104section 145b(1)section 194lakeyman insurancesection 23(2)section 160

Judgments citing (supra), Rama Bai v. CIT

Subhash Chand Dhingra, Gurgaon vs. ACIT Central Circle-3(1), Gurgaon

The appeals are dismissed

ITA 1063/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Feb 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharmasubhash Chand Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Central Circle-3(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aarpd8652J Satish Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-4(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aanpd1971A Ashok Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Abupd6730B Giriraj Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Achpd9434E

For Appellant: Smt. Kavita Jha, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 10(37)Section 139(4)Section 139(5)Section 143Section 143(3)Section 145ASection 263Section 56(2)(viii)Section 57

…F)[2009] 315 ITR 1/182 Taxman 368. The Hon'ble jurisdictional High Court held that in the case of TMK Govindaraju Chetty v. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai &Ors. v. CIT, Andhra Pradesh [181 ITR 400] and K.S. Krishna Rao v. CIT, A.P. [181 ITR 408]; this position of law has been consistently reiterated by Supreme Court by holding that it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. The Hon‟ble High Court dismissed the writ of the assessee in which it was claimed that the said interest did not fall for taxation…

Ashok Kumar Dhingra, Gurgaon vs. ACIT Circle-1(1), Gurgaon

The appeals are dismissed

ITA 1061/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Feb 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharmasubhash Chand Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Central Circle-3(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aarpd8652J Satish Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-4(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aanpd1971A Ashok Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Abupd6730B Giriraj Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Achpd9434E

For Appellant: Smt. Kavita Jha, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 10(37)Section 139(4)Section 139(5)Section 143Section 143(3)Section 145ASection 263Section 56(2)(viii)Section 57

…F)[2009] 315 ITR 1/182 Taxman 368. The Hon'ble jurisdictional High Court held that in the case of TMK Govindaraju Chetty v. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai &Ors. v. CIT, Andhra Pradesh [181 ITR 400] and K.S. Krishna Rao v. CIT, A.P. [181 ITR 408]; this position of law has been consistently reiterated by Supreme Court by holding that it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. The Hon‟ble High Court dismissed the writ of the assessee in which it was claimed that the said interest did not fall for taxation…

Satish Kumar Dhingra, Haryana vs. ACIT Circle-4(1), Gurgaon

The appeals are dismissed

ITA 1060/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Feb 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharmasubhash Chand Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Central Circle-3(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aarpd8652J Satish Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-4(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aanpd1971A Ashok Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Abupd6730B Giriraj Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Achpd9434E

For Appellant: Smt. Kavita Jha, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 10(37)Section 139(4)Section 139(5)Section 143Section 143(3)Section 145ASection 263Section 56(2)(viii)Section 57

…F)[2009] 315 ITR 1/182 Taxman 368. The Hon'ble jurisdictional High Court held that in the case of TMK Govindaraju Chetty v. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai &Ors. v. CIT, Andhra Pradesh [181 ITR 400] and K.S. Krishna Rao v. CIT, A.P. [181 ITR 408]; this position of law has been consistently reiterated by Supreme Court by holding that it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. The Hon‟ble High Court dismissed the writ of the assessee in which it was claimed that the said interest did not fall for taxation…

Bhagwan Vithoba More, Latur vs. Income-Tax Officer, Ward - 1, Latur

Appeal is dismissed in above terms

ITA 1806/PUN/2017[2010-11]Status: DisposedITAT Pune12 May 2022AY 2010-11

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteshri Bhagwan Vithoba More, The Income Tax Officer At Post Kopergaon, Ward -1, Latur Taluka & Dist. Latur Vs. Pan : Azvpm7554P

For Appellant: Shri Sharad A ShahFor Respondent: Shri S.P. Walimbe
Section 10(37)Section 144Section 145ASection 147Section 23Section 23(2)Section 28Section 34Section 45(5)Section 56(2)(viii)

…able to tax under the Income-tax Act .... " (p. 158) 9. This position of law has been consistently reiterated by this Court in the case of T.N.K. Govindaraju Chetty v. CIT [1967J 66 lTR 465, Rama Rai v. CIT [1990]181 ITR 400 and K.S. Krishna Rao v. CIT [1990J 181 ITR 408. Thus, by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt exigible to income-tax. It is true that in amending the definition of 'interest' in section 2(28A), interest was defined to mean interest payable in any manner in respect of any money borrowed or…

Pranav Saran, New Delhi vs. ACIT Circle-32(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 499/DEL/2021[2016-17]Status: DisposedITAT Delhi04 May 2022AY 2016-17

Bench: Shri Amit Shukla & Shri Pradip Kumar Kedia

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Ajay Kumar, Senior DR
Section 10(37)Section 143(3)Section 194LSection 251Section 251(2)Section 28Section 45Section 45(5)Section 56Section 57

…f the act is interest paid for the delayed payment of compensation and therefore it is a revenue receipt liable to tax under the income tax act. iv. The court also considered several decisions of the Hon’ble Supreme Court in case of 66 ITR 465, 181 ITR 400 & 181 ITR 408. v. The Hon’ble court in para number 10 categorically held that interest received as income on the delayed payment of the compensation determined u/s 28 or 31 [?] {sic 34} of the 13 ITA No.499/Del./2021 land acquisition act is taxable event. It held that it is a revenue receipt chargeable to tax u/ s 4 of the act. vi. In that para only the court…

Madhav Pandharinath Kande, Latur vs. Income-Tax Officer

Appeal is dismissed

ITA 2584/PUN/2016[2013-14]Status: DisposedITAT Pune28 Apr 2022AY 2013-14

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteshri Madhav Pandharinath The Income Tax Officer Kande Ward -3 Vs. A/P Dhanora, Tal. Ahmedpur Latur Latur 413515 Pan – Cbwpp1670A Appellant Respondent Appellant By: Shri Bharat Shah Respondent By: Shri S.P. Walimbe Date Of Hearing: 25.04.2022 Date Of Pronouncement: 28.04.2022 O R D E R Per S.S. Godara, Jm This Assessee’S Appeal For Ay 2013-14 Is Against The Order Of The Cit(A) 2, Aurangabad Dated 04.07.2017 Passed In Case No. Pn/Cit (A)-2/Set Aside/Pn/66/2011-12.755 Involving Proceedings Under Section 143(3) R.W.S. 260A Of The Income Tax Act, 1961 In Short The Act.

For Appellant: Shri Bharat ShahFor Respondent: Shri S.P. Walimbe
Section 143(3)Section 23Section 23(1)Section 23(2)Section 28Section 34Section 45Section 56(2)(viii)

…iable to tax under the Income-tax Act .... " (p. 158) 9. This position of law has been consistently reiterated by this Court in the case of T.N.K. GovindarajuChettyv. CIT [1967] 66 ITR 465, Rama Rai v. CIT [1990] 181 ITR 400 and K.S. Krishna Rao v. CIT [1990] 181 ITR 408. Thus, by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt exigible to income-tax. It is true that in amending the definition of 'interest' in section 2(28A), interest was defined to mean interest payable in any manner in respect of any money borrowed or…

Sh. Nitya Nand, Gurgaon vs. ITO, Gurgaon

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 6508/DEL/2016[2013-14]Status: DisposedITAT Delhi30 Jan 2020AY 2013-14

Bench: Shri Bhavnesh Saini & Shri O.P. Kantassessment Year: 2013-14

Section 10Section 10(37)Section 142(1)Section 143(2)Section 143(3)Section 271(1)Section 28Section 44ASection 56(2)(viii)Section 89

…Tax Act. "This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax. Madras [66 ITR 465], Rama Rai & Ors. Vs. CJT, Andhra Pradesh [181 ITR 400] and K.S. Krishna Rao vs. CJT, A. P. [181 ITR 408], Thus by a catena of judicial pronouncements, it is sell led law about the intern received on delayed payment of the compensation is a revenue receipt eligible to income lax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined lo mean interest payable in any manner in respect of any money borrowed or d…

Sh. Balbir Singh, Sirsa vs. Pr. CIT, Hisar

ITA 652/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Gurdeep Singh, Sirsa vs. Pr. CIT, Hisar

ITA 651/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Lakhvinder Singh, Sirsa vs. Pr. CIT, Hisar

ITA 649/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Balwinder Singh, Sirsa vs. Pr. CIT, Hisar

ITA 648/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Baldev Raj, Sirsa vs. Pr. CIT, Hisar

ITA 612/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Jagtar Singh, Sirsa vs. Pr. CIT, Hisar

ITA 610/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Ganesh Dass Mehta, Sirsa vs. Pr. CIT, Hisar

ITA 609/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Bant Singh, Sirsa vs. Pr. CIT, Hisar

ITA 607/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Joginder Singh, Sirsa vs. Pr. CIT, Hisar

ITA 605/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Chadat Singh, Sirsa vs. Pr. CIT, Hisar

ITA 604/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Baldev Singh, Sirsa vs. Pr. CIT, Hisar

ITA 603/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Sh. Kuldeep Singh, Sirsa vs. Pr. CIT, Hisar

ITA 653/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh31 Oct 2018AY 2013-14
For Appellant: Shri. Gautam Jain, Sh. Lalit MohanFor Respondent: Dr. Gulshan Raj
Section 263(1)

…tax Act." This position of law has been consistently reiterated by this Court in the case of TMK Govindaraju Chetty vs. Commissioner of Income-tax, Madras [66 ITR 465], Rama Rai & Ors. vs. CIT, Andhra Pradesh [181 ITR 400] and K.S.Krishna Rao vs. CIT, A. P. [181 ITR 408]. Thus by a catena of judicial pronouncements, it is settled law that the interest received on delayed payment of the compensation is a revenue receipt eligible to income tax. It is true that in amending the definition of "interest" in Section 2(28A) interest was defined to mean interest payable in any manner in respect of any money borrowed or d…

Shri Nitinkumar M. Thaker, Ahmedabad vs. The Income Tax Officer, Ward-14(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 3561/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad04 Oct 2018AY 2008-09

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr

For Appellant: Shri Bhavik J. Shah, A.R
Section 45

…see. The learned AR submitted that as per Section 45 of the Act, the interest on land acquisition is required to be assessed on accrual basis and not on receipt basis in view of the decision of the Hon’ble Supreme Court in the case of K.S. Krishna Rao vs. CIT 181 ITR 408 (SC). The learned AR thereafter referred to the decision of the Hon’ble Delhi High Court in the case of CIT vs. ITA No. 3561/Ahd/15 [Nitinkumar M Thaker vs. ITO] AY 2008-09 - 3 - Satish Kumar Agarwal judgment dated 08.11.2011 for the proposition that rectification under s.154 of the Act is permissible in the light of the decision of the Hon’ble…