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“mistake apparent from record”

Rectification & RevisionSection 154Section 154700 judgments

The decision most relied on for mistake apparent from record is Kourani v. Union OF India (83 Taxmann.com 137), cited in 1,708 judgments on BharatTax.

Leading authorities on mistake apparent from record

Kourani v. Union OF India
83 Taxmann.com 137 · 2017 · High Court
1,708
citing judgments

The fee under Section 234E for late filing of TDS/TCS statements cannot be levied retrospectively by processing an intimation under Section 200A for defaults occurring before the amendment allowing such processing.

ACIT v. Saurashtra Kutch Stock Exchange Ltd.
305 ITR 227 · 2008 · Supreme Court
470
citing judgments

Non-consideration of a decision by a jurisdictional High Court or the Supreme Court constitutes a mistake apparent from the record. However, non-consideration of a non-jurisdictional High Court decision does not typically amount to such a mistake.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

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.

CIT v. Hero Cycles (P.) Ltd.
228 ITR 463 · 1997 · Supreme Court
262
citing judgments

A point not examined on facts or in law cannot be treated as a mistake apparent on record for rectification purposes.

DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
330 ITR 578 · 2011 · High Court
115
citing judgments

Interest under Section 234B is generally not leviable on non-residents whose income is subject to tax deduction at source under Section 195, provided the non-resident assessee did not induce short or non-deduction of TDS by the payer.

CIT v. Aruna Luthra
252 ITR 76 · 2001 · High Court
87
citing judgments

Rectification under Section 154 is permissible based on a subsequent judgment of the Jurisdictional High Court or the Supreme Court. Such a judgment clarifies the law as it always stood, thereby revealing a mistake apparent from the record.

Addl. CIT v. J.K. D'Costa
133 ITR 7 · 1982 · High Court
57
citing judgments

Debatable issues cannot be rectified under Section 154 of the Income-tax Act, as rectification is limited to mistakes apparent from the record.

Mepco Industries Ltd. v. CIT
319 ITR 208 · 2009 · Supreme Court
50
citing judgments

A mistake rectifiable under Section 154 must be obvious and apparent from the record, not one that requires a long process of reasoning or constitutes a mere change of opinion.

Judgments citing mistake apparent from record

DCIT, Cir 8(2) (1), Mumbai vs. M/S. Ogilvy and Mather Pvt. Ltd, Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1637/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 May 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

allowance of depreciation at 60% could not be construed as a hence allowance of depreciation at 60% could not be construed as a mistake apparent from record which could be rectified us. 154 of the mistake apparent from record which could be rectified us. 154 of the mistake apparent from ... provisions of theAct. The power can be exercised, "to it under the provisions of theAct. The power can be exercised, "to rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power

Ogilvy and Mather P. Ltd, Mumbai vs. The Asstt. CIT-8(2)(1), Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1326/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 May 2023AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

allowance of depreciation at 60% could not be construed as a hence allowance of depreciation at 60% could not be construed as a mistake apparent from record which could be rectified us. 154 of the mistake apparent from record which could be rectified us. 154 of the mistake apparent from ... provisions of theAct. The power can be exercised, "to it under the provisions of theAct. The power can be exercised, "to rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power

Ogily and Mather P. Ltd., Mumbai vs. The Asst. CIT -8(2)(1), Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1325/MUM/2021[2013-14]Status: DisposedITAT Mumbai29 May 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

allowance of depreciation at 60% could not be construed as a hence allowance of depreciation at 60% could not be construed as a mistake apparent from record which could be rectified us. 154 of the mistake apparent from record which could be rectified us. 154 of the mistake apparent from ... provisions of theAct. The power can be exercised, "to it under the provisions of theAct. The power can be exercised, "to rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power

Ogilvy and Mather P. Ltd., Mumbai vs. The Asst. CIT-8(2)(1), Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1324/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 May 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

allowance of depreciation at 60% could not be construed as a hence allowance of depreciation at 60% could not be construed as a mistake apparent from record which could be rectified us. 154 of the mistake apparent from record which could be rectified us. 154 of the mistake apparent from ... provisions of theAct. The power can be exercised, "to it under the provisions of theAct. The power can be exercised, "to rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power under rectify any mistake apparent on record." Theexercise of power

Dy. CIT-5(2)(2), Mumbai vs. M/S Vodafone Idea Limited (Earlier Know As Vodafone India Limited Which Now Stands Merged With Idea Cellular Limited (Icl) and Consequently Known As Vodafone Idea Limited), Mumbai

Appeal of the Revenue is dismissed being devoid of any merit

ITA 2429/MUM/2019[2009-10]Status: DisposedITAT Mumbai26 May 2023AY 2009-10

Bench: Shri Vikas Awasthy & Shri M Balaganeshvk-Vk-La- 2429@Eaqcbz@2019 ¼Fu-Oa- 2009&10½ Deputy Commissioner Of Income Tax 5Th Floor, Room No.525, Aayakar Bhavan, M. K. Road, ..... Vihykfkhz/Appellant Mumbai-400 020 Cuke Vs. M/S Vodafone Idea Limited 10Th Floor, Birla Centurion, Pandurang Budhakar Marg, Worli Mumbai-400 030 ..... Izfroknh/Respondent Pan No. Aaach5332B Izr;K{Ksi-La- 32@Eaqcbz@2020 ¼Fu-Oa- 2009&10½ Co No.32/Mum/2020 (A.Y.2009-10) M/S Vodafone Idea Limited 10Th Floor, Birla Centurion, Pandurang Budhakar Marg, Worli Mumbai-400 030 ..... Vihykfkhz/Appellant Pan No. Aaach5332B Cuke Vs. Deputy Commissioner Of Income Tax 5Th Floor, Room No.525, Aayakar Bhavan, M. K. Road, ..... Izfroknh/Respondent Mumbai-400 020

For Appellant: S/Shri P. J. Pardiwala, Sr. Advocate with Ketan Ved izfroknh }kjk@For Respondent: Shri Anand Mohan, CIT-DR
Section 143(3)Section 144C(3)Section 154

NO.32/MUM/2020 (A.Y. 2009-10) M/S. VODAFONE IDEA LIMITED wherever the issue is debatable, it is not a mistake apparent from record and hence, not amenable to proceedings u/s 154 of the Act. The ld. Counsel for the assessee stated at Bar that the assessee has filed Cross Objection in support

Addl. CIT, New Delhi vs. M/S. Mmtc Ltd., New Delhi

ITA 3574/DEL/2017[2009-10]Status: DisposedITAT Delhi24 May 2023AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaaddl. Cit Vs. M/S. Mmtc Ltd. Special Range-6, Core-1, Scope Complex, Room No. 352, Lodhi Road, C.R.Building, I.P.Estate New Delhi New Delhi Pan : Aaacm1433E (Appellant) (Respondent)

Section 143(3)Section 154Section 43B

extent of Rs.6.18 crores remained to be added back to the income of the assessee in the original assessment order, which was a mistake apparent from record. In response to the aforesaid notice, the assessee, vide reply dated 07.01.2014, submitted that the proceedings initiated under section ... Audit Report in Form 3CD as well as provisions of section 43B(f) of the Income Tax Act, 1961 (the Act) was not mistake apparent from record u/s 154 of the Act? 2. Whether on facts and in circumstances of the case, the Ld. CIT(A) is legally justified

Strides Arcolab Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

The appeal of the assessee is allowed

ITA 1903/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 May 2023AY 2010-11

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 10BSection 115JSection 143(3)Section 144CSection 14ASection 35Section 92C

which was apparently mistakenly added back by the AO while computing the book profit under section 115JB of the Act. 6. Rectification of mistake apparent from records The final order passed by the learned AO is suffering from certain mistakes apparent from records particularly with regard to the computation

Shilpa Prabhakar Kulkarni, Mumbai vs. DCIT, CPC, Bengaluru

In the result, the appeal of the assessee is allowed partly for In the result, the appeal of the assessee is allowed partly for In the result, the appeal of the assessee is allowed partly for stati...

ITA 387/MUM/2023[2017-18]Status: DisposedITAT Mumbai11 May 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-2018 Shilpa Prabhakar Kulkarni, Dcit Centralized Processing 3 Neel Sagar, 1280 Prabhadevi Centre, Seaface Prabhadevi, Vs. Bengaluru-560 500. Mumbai-400025. Pan No. Brhpk 8129 D Appellant Respondent Assessee By : Ms. Chandni Shah & Kinjal Patel Revenue By : Mr. A.N. Bhalekar, Dr Date Of Hearing : 03/05/2023 : Date Of Pronouncement 11/05/2023 Order

For Appellant: Ms. Chandni Shah & Kinjal PatelFor Respondent: Mr. A.N. Bhalekar, DR
Section 154Section 234BSection 234C

return of income filed i.e. “Schedule 5; details of income from salary details of income from salary” ”. According to assessee, this was a mistake apparent from record was a mistake apparent from record, in the was a mistake apparent from record intimation issued u/s 143(1) of t intimation issued ... visions of section 154 of the Act are enacted visions of section 154 of the Act are enacted for the purpose of any mistake apparent from record. for the purpose of any mistake apparent from record. for the purpose of any mistake apparent from record. This section is not meant

DCIT Cir 3(3), Mumbai vs. Suparna Chemicals Ltd, Mumbai

In the result, the appeal of the In the result, the appeal of the Revenue on ground No

ITA 7914/MUM/2011[2004-05]Status: DisposedITAT Mumbai11 May 2023AY 2004-05

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2004-05 Dy. Cit-3(3)(2), M/S Suparna Chemicals Room No. 609, 6Th Floor, Ltd., Aayakar Bhavan, M.K. Road, Vs. 54F, Mittal Tower, Mumbai-400020. Nariman Point, Mumbai-400021. Pan No. Aabcs 4578 F Appellant Respondent Assessee By : None Revenue By : Mr. A.N. Bhalekar, Dr : Date Of Hearing 03/05/2023 : Date Of Pronouncement 11/05/2023 Order

For Appellant: NoneFor Respondent: Mr. A.N. Bhalekar, DR
Section 148Section 35ASection 37(1)

simultaneously. In view of the 35AB and section 37(1) of the Act simultaneously. In view of the mistake apparent from record, the Tribunal recalled the appeal to mistake apparent from record, the Tribunal recalled the appeal to mistake apparent from record, the Tribunal recalled the appeal to the extent

Sparrow Security Services, Jammu vs. Income Tax Officer Ward 1(1), Jammu

In the result, the appeal of the assessee bearing ITA No

ITA 40/ASR/2023[2018-19]Status: DisposedITAT Amritsar24 Apr 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 139(1)Section 143(1)Section 143(3)Section 250(6)Section 250oSection 36Section 43B

decided in favour of the assessee by Hon'ble high Court wherein, the adjustment/disallowance made on account of ESI and EPF constituted mistake apparent from record (being in contravention to jurisdictional high court). That the Ld. CIT(A) has erred in ignoring the judgement of Hon'ble Supreme Court ... case of M/s MEPCO INDUSTRIES LIMITED, in which it has been stated that prior mistake apparent from record cannot be rectified/obliterated by subsequent adverse SC JUDGMENT on the same issue. . 5. That the CIT(A) has wrongly placed reliance upon the judgement of apex court in the case of Checkmate

Dy. Commissioner of Income Tax, Central Circle-1(4), Mumbai vs. M/S Essel Minning & Industries Ltd, Mumbai

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

ITA 3160/MUM/2022[2010-2011]Status: DisposedITAT Mumbai18 Apr 2023AY 2010-2011

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2010-11 Dy. Cit Cc-1(4), M/S Essel Minning & 902, 9Th Floor, Pratishtha Industries Ltd., Vs. Bhavan, Old Cgo Bldg. 18Th Floor, Industry House, (Annexe), M.K. Road, 10, Cama Street, Mumbai-400020. Kolkata-700017. Pan No. Aaaci 1747 H Appellant Respondent Assessee By : Mr. Yogesh Thar/ Ms. Sukanya Jayaram/ Mr. Karan Jain, Ar Revenue By : Mrs. Somogyan Pal, Cit-Dr : Date Of Hearing 02/03/2023 Date Of Pronouncement : 18/04/2023 Order

For Appellant: Mr. Yogesh Thar/For Respondent: Mrs. Somogyan Pal, CIT-DR
Section 10BSection 143(3)Section 153C

assessment year 2009-10 and 2010 and 2010-11 to 2011-12 stating that there was a 12 stating that there was a mistake apparent from record and deduction u/s 10B was allowed mistake apparent from record and deduction u/s 10B was allowed mistake apparent from record and deduction ... r.w.s. 1531C) of the Income Tax Act, 1531C) of the Income Tax Act, 1961 dated 29.03.2016. 1961 dated 29.03.2016. Further, rectification of mistakes apparent from records has Further, rectification of mistakes apparent from records has Further, rectification of mistakes apparent from records has been proposed in respect of order passed

Rohit Vijay Singh, Mumbai vs. DCIT/ACIT, CPC, Bangalore, Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 2916/MUM/2022[2018-19]Status: DisposedITAT Mumbai17 Apr 2023AY 2018-19

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blerohit Vijay Singh V. Dcit/Acit 6/603, Dhanalaxmi Building Centralized Processing Centre B-Wing, Mitha Nagar Bangalore M.G. Road, Goregaon (W) Mumbai - 400060 Ward 17(1)(1) Mumbai Kautilya Bhavan Pan: Balps2871R Bandra Kurla Complex Bandra(E), Mumbai - 400050 (Appellant) (Respondent)

Section 128(9)Section 139Section 143Section 143(1)Section 154Section 234Section 90

facts and circumstances of the case in law the erred in rejecting application u/s 154 even though this is a mistake apparent from record. 5. In the facts and circumstances of the case and in law, the learned Commissioner of Income Tax(A) erred in confirming the same by rejecting

Assistant Commissioner of Income Tax (Circle)-6(2)(2), Mumbai vs. Essel Corporate Resources Private Limited, Mumbai

In the result, both the appeals of the revenue are dismissed

ITA 4322/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 Apr 2023AY 2012-13

Bench: Shri M Balaganesh, Am & Shri Pavan Kumar Gadale, Jm आयकरअपीलसं./ I.T.A. No. 4322/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13) आयकरअपीलसं./ I.T.A. No. 3317/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13)

For Appellant: Shri Manoj Kumar, CIT-For Respondent: Shri Madhur Aggarwal, AR
Section 143(3)Section 14ASection 153Section 153(1)(a)Section 154Section 36(1)(iii)Section 37Section 68Section 90

filed a miscellaneous application before the ld. CIT(A) contending that the decision of the ld. CIT(A) suffers from mistake apparent from record leading to erroneous decision in view of the fact that a reference was made to Mauritius Revenue Authority (hereinafter referred ... however, vide order dated 03.04.2017 dismissed the miscellaneous application of the ld. AO holding that there was no such mistake apparent from record. ACIT vs. Essel Corporate Resources Pvt. Ltd. 6. Aggrieved, the revenue has preferred the present appeals before us. 7. We find that in order to address

DCIT 6(2)(2), Mumbai vs. Essel Corporate Resources P.Ltd, Mumbai

In the result, both the appeals of the revenue are dismissed

ITA 3317/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 Apr 2023AY 2012-13

Bench: Shri M Balaganesh, Am & Shri Pavan Kumar Gadale, Jm आयकरअपीलसं./ I.T.A. No. 4322/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13) आयकरअपीलसं./ I.T.A. No. 3317/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2012-13)

For Appellant: Shri Manoj Kumar, CIT-For Respondent: Shri Madhur Aggarwal, AR
Section 143(3)Section 14ASection 153Section 153(1)(a)Section 154Section 36(1)(iii)Section 37Section 68Section 90

filed a miscellaneous application before the ld. CIT(A) contending that the decision of the ld. CIT(A) suffers from mistake apparent from record leading to erroneous decision in view of the fact that a reference was made to Mauritius Revenue Authority (hereinafter referred ... however, vide order dated 03.04.2017 dismissed the miscellaneous application of the ld. AO holding that there was no such mistake apparent from record. ACIT vs. Essel Corporate Resources Pvt. Ltd. 6. Aggrieved, the revenue has preferred the present appeals before us. 7. We find that in order to address

Asst. Commissioner of Income Tax, CC-2, Surat vs. M/S. Hi-Tech Sweet Water Technologies (P) Ltd., Surat

In the result, appeal filed by the Revenue is dismissed

ITA 7/SRT/2023[2019-20]Status: DisposedITAT Surat30 Mar 2023AY 2019-20

Bench: SHRI PAWAN SINGH (Judicial Member), DR. A. L. SAINI (Accountant Member)

For Appellant: Shri Kiran K. Shah, CAFor Respondent: Shri Vinod Kumar, Sr- DR
Section 139Section 143(1)Section 143(3)Section 154Section 80I

horse provisions of section 80IA(7) of the Act and despite there being no mistake apparent from record in the original order. 3) It is, therefore, prayed that the order of the Ld. CIT(A) may be set aside and that of the AO may be restored to the above

Anil Mehta, Pali vs. DCIT, CPC Bangalore / ITO, Ward-1, Pali, Bangalore/Pali

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

ITA 120/JODH/2021[2017-18]Status: DisposedITAT Jodhpur23 Mar 2023AY 2017-18

Bench: Shri Kul Bharat & Shri Manish Borad120/Jodh/2021 (Assessment Year- 2017-18) Vs Dcit Shri Anil Mehta Cpc, Bangalore F-177A, Mandia Road Ind. Area Pali, Marward (Raj) (Appellant) (Respondent) Pan No. Aaypm 7445 B

Section 10Section 143(1)Section 154Section 234B

rejected the request of the appellant for rectification of mistake. I am in agreement with the CPC that there is no mistake apparent from record at the stage of 154 application. If at all, there is any grievance to the appellant, the same had arisen only at the stage

Late Smt. Shanti Devi, Hisar vs. CIT, Hisar

In the result, the appeal of the assessee is allowed

ITA 5074/DEL/2012[2008-09]Status: DisposedITAT Delhi23 Mar 2023AY 2008-09

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Usi.T.A. No. 5074/Del/2012 (A.Y. 2008-09) Ashwani Kumar, Legal Heir Cit, Of Late Smt. Shanti Devi, Vs. Hissar, 14, Urban Estate-Ii, Haryana. Hissar, Haryana. ( Respondent ) Pan No. Anpmd9735C ( Appellant )

For Appellant: Shri Satish Khosla, Adv.; &For Respondent: Shri H. K. Choudhary, [CIT] - D. R
Section 143(1)Section 154Section 263

considered as a mistake apparent of the record and a ground for rectification. In view of the judgements relied upon, the mistake apparent from records in this case, as discussed above in detail, is rectifiable U/s 154 of the Act. 4. On verification, the contention raised by the assessee ... case also in view of the judgements relied upon by the assessee, hence it is exempt U/s 10(37) of the Act. The mistake apparent from records is, therefore, rectified U/s 4 Ashwani Kumar, L.H. Smt. Shanti Devi 154 of the Act, read with Section

Smt. Bhawana Nagori, Bhilwara vs. ITO, Ward-4, Bhilwara

In the result, the appeal of the assessee is allowed

ITA 379/JODH/2019[2010-11]Status: DisposedITAT Jodhpur22 Mar 2023AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Borad379/Jodh/2019 (Assessment Year- 2010-11) Vs The Ito Smt. Bhawna Nagori B-332, Shastri Nagar Ward-4 Bhilwara Bhilwara (Appellant) (Respondent) Pan No. Adlpn 9819 Q

Section 143(3)Section 147Section 148Section 153Section 154Section 234A

months for the period August 2020 to June 2014. I am in agreement with the view of the AO that there was a mistake apparent from record in the assessment order dated 26-03-2015 passed u/s 143(3) r.w.s. 147. As far as the amount of interest charged

Navjeevan Charitable Society, Jalandhar vs. Deputy Commissioner of Income Tax Central Circle-1, Jalandhar

In the result, appeal of the assessee is allowed

ITA 215/ASR/2022[2019-20]Status: DisposedITAT Amritsar20 Mar 2023AY 2019-20

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 142Section 154Section 272ASection 272A(1)(d)Section 273B

this office had taken prior approval of Pr. CIT (Central), Ludhiana and provided the reasonable opportunity of being heard. Therefore, there is no mistake apparent from records and the rectification application filed by the assessee stands rejected. ” (Page 1-2 of Supplementary paper book) In the present case no “direction

Shambhu Dayal Harish Chand Charitable Trust, New Delhi vs. DCIT CPC, Banglore

In the result, the appeal of the assessee is allowed

ITA 4000/DEL/2019[2016-17]Status: DisposedITAT Delhi13 Mar 2023AY 2016-17

Bench: Shri B.R.R. Kumar & Shri Yogesh Kumar U.S.

For Appellant: Ms. Rano Jain, Adv.; &For Respondent: Shri Narpat Singh
Section 11(1)Section 11(2)Section 139(1)Section 143(1)Section 154

dismissed the appeal filed by the assessee vide order dated 08/03/2019 in following manners: “5.1.4. Section 154~provides or mistake apparent from record. In the case under1 consideration as noted above, there is nothing on record i.e., in the income tax return or even the audit report in Form ... Harish Chand Ch. Trust correct his mistake by invoking Section 154 of the Act and the said provision is meant for correcting the mistake apparent on record. Therefore sought for dismissal of the appeal. 7. We have heard the parties and perused the material available on record and gave