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2013 (7) TMI 122

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..... -tax authority may amend any order passed by it under the provisions of this Act or amend any intimation or deemed intimation under sub-section (1) of section 143. Therefore, this Section is very much limited. The error should be apparent from the record. If there exists a debatable issue, if two views are possible, it is not open to the authorities under this proviso to initiate proceedings and r .....

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..... MAR AND B. Manohar, JJ. For the Appellant : K.V. Aravind. For the Respondent : S. Parthasarathi. JUDGMENT: PER: N. Kumar The Search and Seizure operations were mounted on the assessee M/s. Mysore Breweries Limited, Jalahalli Camp Road, Yeswantpur, Bangalore and their sister concerns. Simultaneously, the surveys were conducted under section 133A of the Income-tax Act, 1961 (for s .....

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..... is the Revenue which preferred an appeal to the Income-tax Appellate Tribunal (hereinafter referred to as 'the Tribunal') against the order of the First Appellate Authority. The Tribunal dismissed the appeal holding that the order of the Assessing Officer was reappraisal of the facts and evidences and he has come to a different conclusion. It is held that rectification is permissible in the proce .....

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..... Income-tax authority may amend any order passed by it under the provisions of this Act or amend any intimation or deemed intimation under sub-section (1) of section 143. Therefore, this Section is very much limited. The error should be apparent from the record. If there exists a debatable issue, if two views are possible, it is not open to the authorities under this proviso to initiate proceeding .....

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