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2011 (10) TMI 468 - HC - Income TaxAppeal against rectification order passed by Assessing Officer (suo- moto) u/s 154 - assessee contended that very purpose of invoking Section 154 would be lost if further details are called for from the assessee - Held that:- The very fact that the AO called upon the assessee to furnish the details of Rs. 28,10,000/- towards the payments made by them to the Sales Tax Department to substantiate their claim would indicate they expected reply and further enquiry into the matter to know whether the assessee was entitled for such allowance or not. This is nothing but the authorities concerned were accepting the long drawn litigation to arrive at the conclusion after obtaining the details from the respondent-assessee, which is very much against the Provision of Section 154 as laid down in the case of T.S. Balaram, ITO v. Volkart Brothers [1971 -TMI - 6255 - SUPREME Court]. Therefore, there was no obvious and patent mistake on the face of record, which compelled the AO to initiate the proceedings u/s 154 - Decided in favor of the assessee
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