Section 154 not invocable for Rectification of Debatable Issues: ITAT Delhi

Beacon Higher Education Services Pvt Ltd Vs ACIT (ITAT Delhi)

ITAT Delhi held that issue relating to allowance of depreciation on non-compete fee is debatable and it is well settled law that rectification provision u/s. 154 of the Income Tax Act cannot be invoked if the issue is debatable.

Facts- The assessee, a company, filed its return of income at NIL after setting off of the brought forward losses of Rs. 4,29,60,688/-under normal provisions of the Income-tax Act, 1961 and book profit of Rs. 57,22,914/- u/s 115JB of the Act.

The case was taken up f

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