Section 154 cannot be invoked on debatable issues

South West Pinnacle Exploration Ltd. Vs ACIT (ITAT Delhi)

Rectification under section 154 of the Act can only be made when glaring mistake of fact or law has been committed by the officer passing the order becomes apparent from the record. Rectification is not possible if the question is debatable. Moreover, the point which was not examined on facts or in law cannot be dealt as mistake apparent on the record. The dispute raised a mixed question of fact and law.

FULL TEXT OF THE ORDER OF ITAT DELHI

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