If Applicability of Section 115JB is Debatable, then Rectification Beyond Section 154 Scope

ACIT vs National Dairy Development Board (ITAT Ahmedabad) ITAT Ahmedabad held that issue of applicability of section 115JB to National Dairy Development Board is debatable and not a mistake apparent from record hence rectification order passed is beyond the scope of section 154 of the Income Tax Act. Facts- The present appeals are filed by the Revenue as against the appellate orders arising against rectification and assessment orders passed under Section 154 and 143(3) of the Income-tax Act, 1961 for Assessment Years 2010–11 to 2013–14. Since the common issue of applicability of the provis...