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2012 (6) TMI 209 - AT - Income TaxAllowance of debenture redemption reserve and short provision of expenses - invoking Section 154 by A.O. as the assessee did not include the two while determining book profits u/s 115JB – Held that:- if the issue requires debate and discussion, it cannot become a subject-matter of rectification under section 154 of the Act because under this section only patent and obvious mistakes of law and facts can be rectified - it is not open to the AO to go into the true scope of the relevant provisions of the Act in proceedings under section 154 - T.S.Balaram, ITO Vs. Volkart Brothers& Others [1971 (8) TMI 3 (SC)]- as the facts of the case were debatable questions but when the Revenue have not placed any material in order to controvert findings of the ld. CIT(A) nor even pointed out any contrary decision while the issues are debatable no need to interfere with the conclusion of the ld. CIT(A) – against revenue
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