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2010 (7) TMI 626 - HC - Income TaxReopening - Rectification of mistakes - Deduction u/s 80HHC - It is well settled that the power of rectification can be invoked only to correct a mistake apparent on the face of the record and cannot be exercised on a debatable issue - Assessing Officer cannot simultaneously proceed under sections 147 and 154 of the Act.Section 154(7) of the Act prescribes limitation for amending any order passed under the Act by rectifying any mistake apparent on the face of the record - Notice under section 154 of the Act having been issued on January 23, 2002, was clearly barred by time and thus, initiation of action was invalid - Held that: there was no impediment before the Assessing Officer to initiate reassessment proceedings after complying with the requirements of sections 147 and 148 of the Act, for which notice was issued on March 22, 2002 - Decided against the assessee
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