Section 154 can not be applied if a debatable point involved

Mistake apparent on the record u/s 154 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.

This interpretation made by Hon’ble Supreme Court in case of T.S. Balaram, ITO v. Volkart Brothers [1971] 82 ITR 50, was followed by Delhi High Court in the present case. The assessee, in the present case, claimed business e

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