No section 154 Rectification by AO in case of Debatable Issues

Avisha Credit Capital Ltd. Vs ITO (ITAT Delhi) Undisputedly, the loss from sale of shares was debited to profit and loss account as trading loss. While completing the assessment under section 143(3) of the Act, the Assessing Officer obviously has accepted the claim. The Assessing Officer has initiated proceeding under section 154 of the Act qua the claim of loss on the ground that the shares were held as investment and not as stock in trade. It is observed, in reply to show-cause notice issued under section 154 of the Act, the assessee has clearly and categorically submitted that the shares we...