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2023 (12) TMI 278 - AT - Income TaxRectification u/s 154 - Disallowance of prior period expenses - Revenue has vehemently argued before us that the Assessing Officer had rightly initiated the impugned rectification process for the purpose of disallowing the assessee’s foregoing prior period expenses - HELD THAT: He fails to dispute the clinching fact emerging from the case records that the AO had very well issued sec. 142(1) notice seeking to disallow the same on 26.02.2016 i.e., prior to sec. 143(3) assessment which stood duly explained by the assessee on 08.03.2016. These relevant documents duly form part of the case records. That being the case, we quote hon’ble apex court’s landmark decision in T.S. Balram, ITO vs. Volkart Brothers [1971 (8) TMI 3 - SUPREME COURT] that purpose of sec. 154 rectification is only to deal with apparent mistakes on record than those involving detailed roving enquiries and confirm the CIT(A)'s action reversing the AO’s impugned action to this effect. Appeal is dismissed.
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