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2023 (4) TMI 475 - AT - Income TaxRectification u/s 154 - two different opinions possible - enhancing the income of the assessee on the ground that there was an error in computation of the MAT during the course of proceedings u/s. 143(3) on the quantum amount as claimed by the assessee as deduction u/s. 80IB of the Act on the surrendered income during the course of search/survey - HELD THAT:- On going through the order of the CIT(Appeals), we note that there is no basis on the material available on record so that it could be said that there was a mistake apparent from the record and if there are two possible opinions, the same cannot be subject of rectification u/s. 154 of the Act. The case law relied on by the ld. DR is not applicable to the facts of the present case. Issue decided in favour of assessee as decided in assessee own case [2022 (10) TMI 340 - ITAT BENGALURU] as held that invoking section 154 would be untenable when the matter requires adjudication upon the issue which is debatable issue - AO is not correct in enhancing the book profits u/s.115JC by passing an order under Section 154 - Decided against revenue.
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