Section 154 cannot be invoked for Applicability of section 14A to section 115JB provisions

DCIT Vs Jammu Pigments Ltd. (ITAT Delhi) Assessing Officer initiated proceeding under section 154 of the Act to make the disputed disallowance while computing the book profit and ultimately did so. Therefore, it is evident, the 154 proceeding was at the behest of the Revenue audit. Applicability of section 14A read with Rule 8D to the provisions of section 115JB certainly is a highly debatable issue. Hence, it will not fall within the category of mistake apparent on the face of record as envisaged under section 154 of the Act. In any case of the matter, in case of ACIT Vs. Vireet Investment Pv...