T.S. Balaram ITO v. Volkart Bros.

82 ITR 50Supreme Court of India1971#194 most cited

What is T.S. Balaram ITO v. Volkart Bros. authority for?

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

382

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2011 to 2026.

Also referred to as

T.S. Balaram v. Volkart Bros. · 82 ITR 50 · Section 154 · mistake apparent from record · rectification · obvious and patent mistake · change of opinion · scope of rectification · long drawn reasoning

Sections most often in play

Section 154Section 143(3)Section 250Section 153ASection 69Section 263Section 245D(4)Section 245D(6B)

Issues it is cited on

mistake apparent from recordrectification u/s 154mistake apparent on recordsection 154change of opinionregular assessmentsection 15section 24section 234section 23income-tax officerprevious year

Judgments citing T.S. Balaram ITO v. Volkart Bros.

Snehil Welfare Trust, Hyderabad vs. Income Tax Officer, Ward-1, Hyderabad

In the result, appeals filed by the respective assessees are allowed

ITA 1476/HYD/2018[2014-15]Status: DisposedITAT Hyderabad15 Mar 2019AY 2014-15

Bench: Smt. P. Madhavi Devi

For Appellant: Shri A. SrinivasFor Respondent: Shri D.J.Prabhakar Anand
Section 143(1)Section 154Section 167B

…ter a long drawn process and therefore, it cannot be stated to be a mistake apparent from the record which could be reviewed u/s 154 of the Act. In support of his contention he placed reliance upon the following case law: i) T.S. Balaram ITO vs. Volkart Bros. 82 ITR 50 (S.C) ii) IInd Additional ITO vs. Atmala Nagaraju – 46 ITR (S.C) iii) CIT vs. Keshri Metal P Ltd- 237 ITR 165 (S.C) 5. Further, he submitted that the assessee being a Trust and beneficiary being a single person and the Trustees not being the beneficiaries, the AOP has to be taxed at individual tax rates only. In support of this contention, he plac…

Snehil Welfare Trust, Hyderabad vs. Income Tax Officer, Ward-1, Hyderabad

In the result, appeals filed by the respective assessees are allowed

ITA 1475/HYD/2018[2013-14]Status: DisposedITAT Hyderabad15 Mar 2019AY 2013-14

Bench: Smt. P. Madhavi Devi

For Appellant: Shri A. SrinivasFor Respondent: Shri D.J.Prabhakar Anand
Section 143(1)Section 154Section 167B

…ter a long drawn process and therefore, it cannot be stated to be a mistake apparent from the record which could be reviewed u/s 154 of the Act. In support of his contention he placed reliance upon the following case law: i) T.S. Balaram ITO vs. Volkart Bros. 82 ITR 50 (S.C) ii) IInd Additional ITO vs. Atmala Nagaraju – 46 ITR (S.C) iii) CIT vs. Keshri Metal P Ltd- 237 ITR 165 (S.C) 5. Further, he submitted that the assessee being a Trust and beneficiary being a single person and the Trustees not being the beneficiaries, the AOP has to be taxed at individual tax rates only. In support of this contention, he plac…

Shreeya Welfare Trust, Hyderabad vs. Income Tax Officer, Ward-1, Hyderabad

In the result, appeals filed by the respective assessees are allowed

ITA 1474/HYD/2018[2015-16]Status: DisposedITAT Hyderabad15 Mar 2019AY 2015-16

Bench: Smt. P. Madhavi Devi

For Appellant: Shri A. SrinivasFor Respondent: Shri D.J.Prabhakar Anand
Section 143(1)Section 154Section 167B

…ter a long drawn process and therefore, it cannot be stated to be a mistake apparent from the record which could be reviewed u/s 154 of the Act. In support of his contention he placed reliance upon the following case law: i) T.S. Balaram ITO vs. Volkart Bros. 82 ITR 50 (S.C) ii) IInd Additional ITO vs. Atmala Nagaraju – 46 ITR (S.C) iii) CIT vs. Keshri Metal P Ltd- 237 ITR 165 (S.C) 5. Further, he submitted that the assessee being a Trust and beneficiary being a single person and the Trustees not being the beneficiaries, the AOP has to be taxed at individual tax rates only. In support of this contention, he plac…

Shreeya Welfare Trust, Adilabad vs. Income Tax Officer, Ward-1, Adilabad

In the result, appeals filed by the respective assessees are allowed

ITA 1473/HYD/2018[2014-15]Status: DisposedITAT Hyderabad15 Mar 2019AY 2014-15

Bench: Smt. P. Madhavi Devi

For Appellant: Shri A. SrinivasFor Respondent: Shri D.J.Prabhakar Anand
Section 143(1)Section 154Section 167B

…ter a long drawn process and therefore, it cannot be stated to be a mistake apparent from the record which could be reviewed u/s 154 of the Act. In support of his contention he placed reliance upon the following case law: i) T.S. Balaram ITO vs. Volkart Bros. 82 ITR 50 (S.C) ii) IInd Additional ITO vs. Atmala Nagaraju – 46 ITR (S.C) iii) CIT vs. Keshri Metal P Ltd- 237 ITR 165 (S.C) 5. Further, he submitted that the assessee being a Trust and beneficiary being a single person and the Trustees not being the beneficiaries, the AOP has to be taxed at individual tax rates only. In support of this contention, he plac…

Shreeya Welfare Trust, Adilabad vs. Income Tax Officer, Ward-1, Adilabad

In the result, appeals filed by the respective assessees are allowed

ITA 1472/HYD/2018[2013-14]Status: DisposedITAT Hyderabad15 Mar 2019AY 2013-14

Bench: Smt. P. Madhavi Devi

For Appellant: Shri A. SrinivasFor Respondent: Shri D.J.Prabhakar Anand
Section 143(1)Section 154Section 167B

…ter a long drawn process and therefore, it cannot be stated to be a mistake apparent from the record which could be reviewed u/s 154 of the Act. In support of his contention he placed reliance upon the following case law: i) T.S. Balaram ITO vs. Volkart Bros. 82 ITR 50 (S.C) ii) IInd Additional ITO vs. Atmala Nagaraju – 46 ITR (S.C) iii) CIT vs. Keshri Metal P Ltd- 237 ITR 165 (S.C) 5. Further, he submitted that the assessee being a Trust and beneficiary being a single person and the Trustees not being the beneficiaries, the AOP has to be taxed at individual tax rates only. In support of this contention, he plac…

Income Tax Officer, Bangalore vs. Late Smt. Lakshmamma, Bangalore

In the result, all the appeals of the revenue are treated as allowed for statistical purposes

ITA 1696/BANG/2016[2007-2008]Status: DisposedITAT Bangalore20 Feb 2019AY 2007-2008

Bench: Shri N.V.Vasudevan, Vp & Shri B.R.Baskaran, Am

For Respondent: Miss Neera Malhotra, CIT-DR
Section 143(3)Section 154

…they could have made only through revised return of income, as per the decision rendered by the Hon’ble Supreme Court in the case of Goetz (India) Ltd. The A.O. also took support of the decision rendered in the case of T.S.Balaram, ITO v. Volkari Bros (1971) 82 ITR 40], wherein it was held that a mistake apparent on the record must be and obvious and patent mistake and not something which can be established by a long drawn process or reasoning on points on which there may be conceivably two opinions. Accordingly, the A.O. took the view that the rectification petition filed by the assessees u/s 154 of the Act is…

Income Tax Officer, Bangalore vs. Late Smt. Lakshmamma, Bangalore

In the result, all the appeals of the revenue are treated as allowed for statistical purposes

ITA 1695/BANG/2016[2006-07]Status: DisposedITAT Bangalore20 Feb 2019AY 2006-07

Bench: Shri N.V.Vasudevan, Vp & Shri B.R.Baskaran, Am

For Respondent: Miss Neera Malhotra, CIT-DR
Section 143(3)Section 154

…they could have made only through revised return of income, as per the decision rendered by the Hon’ble Supreme Court in the case of Goetz (India) Ltd. The A.O. also took support of the decision rendered in the case of T.S.Balaram, ITO v. Volkari Bros (1971) 82 ITR 40], wherein it was held that a mistake apparent on the record must be and obvious and patent mistake and not something which can be established by a long drawn process or reasoning on points on which there may be conceivably two opinions. Accordingly, the A.O. took the view that the rectification petition filed by the assessees u/s 154 of the Act is…

Income Tax Officer, Bangalore vs. Late Sri.A.S.Narayana Raju, Bangalore

In the result, all the appeals of the revenue are treated as allowed for statistical purposes

ITA 1694/BANG/2016[2007-2008]Status: DisposedITAT Bangalore20 Feb 2019AY 2007-2008

Bench: Shri N.V.Vasudevan, Vp & Shri B.R.Baskaran, Am

For Respondent: Miss Neera Malhotra, CIT-DR
Section 143(3)Section 154

…they could have made only through revised return of income, as per the decision rendered by the Hon’ble Supreme Court in the case of Goetz (India) Ltd. The A.O. also took support of the decision rendered in the case of T.S.Balaram, ITO v. Volkari Bros (1971) 82 ITR 40], wherein it was held that a mistake apparent on the record must be and obvious and patent mistake and not something which can be established by a long drawn process or reasoning on points on which there may be conceivably two opinions. Accordingly, the A.O. took the view that the rectification petition filed by the assessees u/s 154 of the Act is…

Income Tax Officer, Bangalore vs. Late Sri.A.S.Narayana Raju, Bangalore

In the result, all the appeals of the revenue are treated as allowed for statistical purposes

ITA 1693/BANG/2016[2006-07]Status: DisposedITAT Bangalore20 Feb 2019AY 2006-07

Bench: Shri N.V.Vasudevan, Vp & Shri B.R.Baskaran, Am

For Respondent: Miss Neera Malhotra, CIT-DR
Section 143(3)Section 154

…they could have made only through revised return of income, as per the decision rendered by the Hon’ble Supreme Court in the case of Goetz (India) Ltd. The A.O. also took support of the decision rendered in the case of T.S.Balaram, ITO v. Volkari Bros (1971) 82 ITR 40], wherein it was held that a mistake apparent on the record must be and obvious and patent mistake and not something which can be established by a long drawn process or reasoning on points on which there may be conceivably two opinions. Accordingly, the A.O. took the view that the rectification petition filed by the assessees u/s 154 of the Act is…

ACIT 2(2)(1), Mumbai vs. Icici Prudential Amc Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3540/MUM/2017[2007-08]Status: DisposedITAT Mumbai30 Jan 2019AY 2007-08

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Blea.C.I.T, Circle – 2(2)(1) V. M/S. Icici Prudential Amc Ltd., Room No. 545, 5Th Floor, 8Th Floor, Peninsula Tower, Aayakar Bhavan, M.K. Road, Peninsula Corporate Park, Mumbai-400 020 Lower Parel, Mumbai- 400 013 Pan: Aaaci 1000 K (Appellant) (Respondent) Assessee By : None Department By : Shri Abi Rama Kartikeyan

For Appellant: NoneFor Respondent: Shri Abi Rama Kartikeyan
Section 154Section 156Section 244(1)Section 244ASection 244A(1)Section 244A(1)(a)Section 244A(1)(b)

…r debate. It, therefore, follows that a decision on the debatable point of law or fact or failure to apply the law to a set of facts, which remains to be investigated, cannot be corrected by way of rectification u/s. 154 of the Act. (iv) ITO v. Volkart Bros. (82 ITR 50)(SC) wherein the Hon'ble Supreme Court has held that a mistake apparent on the record must be an obvious and patent mistake and not something which can be established by a long drawn process of reasoning of points on which there may be conceivably two opinions. A decision on a debatable point of law is not a mistake apparent from the record. (v) CI…

Bhima Dada Kharate, Nashik vs. Assistant Commissioner of Income-Tax, Circle -1, Nashik

Appeal of the assessee is allowed

ITA 1598/PUN/2017[2011-12]Status: DisposedITAT Pune21 Jan 2019AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Pramod ShingteFor Respondent: Shri Sudhendu Das
Section 143(3)Section 148Section 2(14)Section 54BSection 55A

…y because the AO has made a reference to the DVO after the date of such amendment for an assessment year prior to the amendment is a highly debatable issue. The Hon’ble Supreme Court in the case of T.S. Balaram, ITO Vs. Volkart Brothers and Others reported in 82 ITR 50 has held that a mistake apparent on the record must be an obvious patent mistake and not something which can be established by a long run process of reasoning on points on which there may be conceivably two opinions. A decision on a debatable point of law is not a mistake apparent from the record. Since in the instant case the issue as to whether t…

Balu Vitthal Kharate, Nashik vs. Assistant Commissioner of Income-Tax, Circle - 1, Nashik

Appeal of the assessee is allowed

ITA 1596/PUN/2017[2011-12]Status: DisposedITAT Pune21 Jan 2019AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Pramod ShingteFor Respondent: Shri Sudhendu Das
Section 143(3)Section 148Section 2(14)Section 54BSection 55A

…y because the AO has made a reference to the DVO after the date of such amendment for an assessment year prior to the amendment is a highly debatable issue. The Hon’ble Supreme Court in the case of T.S. Balaram, ITO Vs. Volkart Brothers and Others reported in 82 ITR 50 has held that a mistake apparent on the record must be an obvious patent mistake and not something which can be established by a long run process of reasoning on points on which there may be conceivably two opinions. A decision on a debatable point of law is not a mistake apparent from the record. Since in the instant case the issue as to whether t…

Assocaiation of State Road Transport Undertaking, New Delhi vs. ADIT(Exemption), Delhi

In the result, whereas appeal of the revenue is dismissed, the appeal of the assessee is allowed for statistical purposes

ITA 1724/DEL/2016[2010-11]Status: DisposedITAT Delhi29 Nov 2018AY 2010-11

Bench: Shri Prashant Maharishi & Shri K.Narasimha Charyassessment Year: 2010-11 Asstt. Comr. Of Income-Tax (E), Vs M/S Association Of Road Transport Circle 1(1), New Delhi. Undertaking, Plot No.4A, Psp Block, Pkt. 14, Sector-8, Dwarka, New Delhi. Pan: Aaaaa0233A Assessment Year: 2010-11 M/S Association Of Road Transport Undertaking, Vs. Adit (E), Plot No.4A, Psp Block, Pkt. 14, Circle 1(1), New Delhi. Sector-8, Dwarka, New Delhi . Pan: Aaaaa0233A (Appellant) (Respondent) Assessee By: Shri Tarandeep Singh Revenue By: Shri Surender Pal, Sr. Dr Date Of Hearing: 26.11.2018 Date Of Pronouncement: 29.11.2018 Order Per K. Narasimha Chary, Jm

For Appellant: Shri Tarandeep SinghFor Respondent: Shri Surender Pal, Sr. DR
Section 10Section 12ASection 154Section 2(15)

…Court in the case of CIT vs. A.G. Granites (P) Ltd.{Tax Case(Appeal) No.946 of 2007} is not available to be dealt with u/s 154 of the Act. Assessee placed reliance on the decision of the Hon’ble Supreme Court in the case of T.S. Balram, ITO vs. Volkart Bros., 82 ITR 50 for the principle that a 3 mistake apparent on the 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 be conceivably two opinions and a decision on a debatable point of law is not a mistake apparent from the record which is not amenable for recti…

ACIT (E), New Delhi vs. M/S Association of Road Transport Undertakings, New Delhi

In the result, whereas appeal of the revenue is dismissed, the appeal of the assessee is allowed for statistical purposes

ITA 1252/DEL/2016[2010-11]Status: DisposedITAT Delhi29 Nov 2018AY 2010-11

Bench: Shri Prashant Maharishi & Shri K.Narasimha Charyassessment Year: 2010-11 Asstt. Comr. Of Income-Tax (E), Vs M/S Association Of Road Transport Circle 1(1), New Delhi. Undertaking, Plot No.4A, Psp Block, Pkt. 14, Sector-8, Dwarka, New Delhi. Pan: Aaaaa0233A Assessment Year: 2010-11 M/S Association Of Road Transport Undertaking, Vs. Adit (E), Plot No.4A, Psp Block, Pkt. 14, Circle 1(1), New Delhi. Sector-8, Dwarka, New Delhi . Pan: Aaaaa0233A (Appellant) (Respondent) Assessee By: Shri Tarandeep Singh Revenue By: Shri Surender Pal, Sr. Dr Date Of Hearing: 26.11.2018 Date Of Pronouncement: 29.11.2018 Order Per K. Narasimha Chary, Jm

For Appellant: Shri Tarandeep SinghFor Respondent: Shri Surender Pal, Sr. DR
Section 10Section 12ASection 154Section 2(15)

…Court in the case of CIT vs. A.G. Granites (P) Ltd.{Tax Case(Appeal) No.946 of 2007} is not available to be dealt with u/s 154 of the Act. Assessee placed reliance on the decision of the Hon’ble Supreme Court in the case of T.S. Balram, ITO vs. Volkart Bros., 82 ITR 50 for the principle that a 3 mistake apparent on the 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 be conceivably two opinions and a decision on a debatable point of law is not a mistake apparent from the record which is not amenable for recti…

Sunland Alloys, Delhi vs. ACIT, New Delhi

In the result, the appeal filed by the Assessee stands allowed

ITA 209/DEL/2015[2010-11]Status: DisposedITAT Delhi16 Nov 2018AY 2010-11

Bench: Shri H. S. Sidhu & Shri N.K. Billaiya

For Appellant: SH. SACHIN KUMAR, CAFor Respondent: SH. AMIT KATOCH, SR. DR
Section 143(2)Section 143(3)Section 154Section 234DSection 244ASection 80I

…the relief granted under the section could not be said to be a mistake apparent from the record, within the meaning of s. 154 of the Act. 3. While interpreting the scope of s. 154 of the Act, the Supreme Court in T.s. Balaram, ITO vs. Volkart Brothers (1971) 82 ITR 50 (SC), held that a mistake apparent on the record within the meaning of s. 154 of the Act 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 be conceivably two opinions. A decision on a debatable point of law is not a mistake apparent from the record.…

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

…ght to be set aside and the income as per the order of assessment dated 26.03.2014 restored. 5.1.3 In support of the assessee’s plea, the learned AR placed reliance on the following judicial pronouncements: (i) T. S. Balaram, ITO Vs. Volkart Brothers (1971) 82 ITR 50 (SC). (ii) K. S. Venkatesh Vs. DCIT (2015) 63 taxman.com 343 (Karnataka); which followed the aforesaid decision of the Hon’ble Apex Court (supra). According to the learned AR, the rectification undertaken by the AO is in respect of debatable issues with regard to the computation of partners’ salary and also Page 6 of 9 as to whether the claim mad…

M/S. Ajay Kumar Gupta (HUF), Delhi vs. ACIT, New Delhi

In the result, the appeal is allowed

ITA 5775/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2018AY 2010-11

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahuassessment Year:

Section 139(1)Section 139(4)Section 139(5)Section 154Section 234BSection 40Section 80C

…ke, which is required to be established by long drawn process of reasoning on points. 3.2 The scope and amplitude of section 154 of the Income-tax Act, 1961, has been considered by the Supreme court in the case of T.S. Balaram, ITO v. Volkart Brothers [1971] 82 ITR 50 wherein it was held that a mistake apparent on the 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 be conceivably two opinions. A decision on a debatable point of law is not a mistake apparent from the record, which is not amenable for rectific…

ACIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3445/MUM/2017[2005-06]Status: DisposedITAT Mumbai27 Sept 2018AY 2005-06

Bench: Shri R.C.Sharma, Am & Shri Sandeep Gosain, Jm Dcit – Circle – 2(3)(2) Vs. M/S. Icici Bank Ltd., R.No.552, 5Th Floor Icici Bank Towers Aayakar Bhavan South East Wing 9Th M.K.Road, Floor, Bandra Kurla Mumbai-400020 Complex, Bandra (E) Mumbai – 400 051 Pan/Gir No.Aaaci1195H (Appellant) .. (Respondent)

Section 115JSection 143(3)Section 147Section 154Section 88Section 88E

…not something which can be established by a long-drawn process of reasoning on points on which there may be conceivably two opinions, A decision on a debatable point of law is not a mistake apparent from the record. [T.S. Balaram, /TO v. Volkart Bros. [1971] 82 ITR 50 (SC)]. It has further been held by the Apex Court in the case of C/T v. Hero Cycles. (P.) Ltd. [1997] 228 ITR 463/ 94 Taxman 271 that 'A point which was not examined on facts or in law cannot be dealt with as a mistake apparent from the record'. 5.2.5 In the instant case, the issue of whether or not the impugned rebate was claimed was not examined…

DCIT 8(3)(2), Mumbai vs. Voltas Ltd, Mumbai

In the result, the appeal Revenue is dismissed

ITA 2521/MUM/2015[2009-10]Status: DisposedITAT Mumbai10 Jul 2018AY 2009-10

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: Shri Saurabh Kumar RaiFor Respondent: Shri Nitesh Joshi, AR
Section 143(1)Section 143(3)Section 144C(3)Section 154Section 156Section 199Section 206CSection 244ASection 244A(1)(b)

…ot limited to clerical or arithmetical mistakes only. However it does not include any mistake which may be discovered by a complicated process of investigation, argument or proof. Reference in this regard may be made to T.S. Balaram, ITO v Volkart Bros (1971) 82 ITR 40 (SC). A decision on a is not a mistake apparent from the record. The ordinary meaning of the word “apparent” is that it should be something, which appears to be so ex facie that it does not admit scope for any argument or debate. It, therefore, follows that a decision on a debatable point of law or fact or failure to apply the law to a set of facts…

Maya Entertainment Ltd., Mumbai vs. ACIT - 11(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5089/MUM/2016[2009-10]Status: DisposedITAT Mumbai15 Jun 2018AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Blem/S. Maya Entertainment Ltd., V. The Asstt. Cit – 11(1) Room No. 467, 4Th Floor, 23, Shah Industrial Estate Aayakar Bhavan, M.K. Road, Off. Veera Desai Road, Mumbai-400 020 Andheri (W), Mumbai – 400 053

For Appellant: Shri S.C. TiwariFor Respondent: Shri V. Vidyadhar
Section 115JSection 143(3)Section 154Section 36Section 36(1)(vii)

…sion of the 6 M/s. Maya Entertainment Ltd., Hon'ble Supreme Court and subsequent decisions and hence outside the scope of section 154 of the Act. Relying on the decision of the Supreme Court in the case of T.S. Balaram, Income Tax Officer v. Volkart Brothers [82 ITR 50], Learned Counsel for the assessee submitted that the Hon'ble Supreme Court held that a mistake apparent on 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 conceivable be two opinions. 8. Ld. DR vehemently supported the orders of the Ld.CIT(A)…