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2013 (11) TMI 1248 - HC - Income TaxRectification of mistake - Tax and other statutory liabilities – Held that:- The assessee had incurred liabilities in respect of deductions in the assessment year in question i.e. 1984-85. It is also not disputed that the deductions, except dues of PF, are covered under Section 43-B of the Act and thus the first proviso to Section 43-B, with retrospective effect will apply - The dues of PF are also covered by second proviso to Section 45-B which was in force in the relevant assessment year i.e. 1984-85 – This is a debatable issue. In the debatable issue proceedings under Section 154 cannot be taken up - Following T.S. Balaram, Income Tax Officer, Company Circle IV. Bombay Vs. Volkart Brothers and others [1971 (8) TMI 3 - SUPREME Court] - A mistake apparent on the record must be an obvious and patent mistake and not something which can be established by a long drawn process of reasoning on points on which there may be conceivably two opinions. A decision on debatable point of law is not a mistake apparent from the record – Decided against Revenue.
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