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2016 (2) TMI 709 - HC - Income TaxApplicability of Section 154 - Rectification of mistake - permissibility of computation of deduction under Section 80HHC - Held that:- No error can be said to be apparent on the face of the record, when it is not manifest or self-evident, but requires an examination or argument to establish it. Admittedly, the issue involved pertains to permissibility of computation of deduction under Section 80HHC of the Act, by excluding 90% of the gross lease income from the business profits. The issue admittedly involves closer scrutinity/ examination of facts and application of law to the facts stated supra and therefore, the mistake cannot be construed to be apparent on the face of the record. Therefore, the Assessing Officer has no jurisdiction to invoke Section 154 of the Act, while making the assessment order dated 27.06.2001. Therefore, the order by the Tribunal upholding the same has to be set aside.
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