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2023 (9) TMI 498 - HC - Income TaxRectification u/s 154 - Unexplained cash - disclosure of cash was neither accepted nor was any explanation/clarification furnished by the concerned firm M/s. M.K. Ceramics during the course of assessment proceedings - Tribunal held that the provision of Section 154 of the Act can be invoked when there is a mistake which is apparent from record and about the same two views are not possible and AO has committed an error by passing the order for rectification of the assessment order under the provisions of Section 154 - HELD THAT:- We have perused the orders passed by the CIT(A) as well as the Tribunal who have arrived at concurrent findings of fact to the effect that there is no mistake apparent on record and when there are two views possible on the same facts, the Assessing Officer could not have invoked the provisions under Section 154 of the Act. When the Assessing Officer has accepted the contention of assessee while framing the regular assessment, there is no mistake apparent on record as rightly held by both CIT(A) and the Tribunal and therefore we are of the opinion that no question of law much less any substantial question of law arises from the impugned order passed by the Tribunal.
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