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 expenditure u/s 43B to the tune of Rs.9132404 paid to Cooperative Education Fu...