Rectification u/s 154 of non-inclusion of surrendered income in book profits u/s 115JB not amenable

SETCO Automotive Ltd. Vs ACIT (ITAT Ahmedabad) Held that the non-inclusion of surrendered income in the Book Profits of the assessee as per section 115JB of the Act, was not a patent error amenable to rectification u/s 154 of the Income Tax Act. Facts- The rectification made by the AO in the impugned case was in relation to adjustment made to the book profits of the assessee by adding thereto amount of income surrendered by the assessee during survey of Rs.17 crores. The AO had noted that while the assessee had included the surrendered income for the purpose of computing its income for taxatio...