2013 (7) TMI 122

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..... e 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 short, hereinafter referred to as 'the Act') at the assessee's Units at Tumkur, Peenya, Bangalore. The assets that were found, seized and were adjusted against th .....

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..... e 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 proceedings with regard to total mistakes, under section 154 of the Act. Therefore, the appeal filed by the Revenue came to be dismissed. Aggrieved by the said order, .....

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..... 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 revise its opinion. All that it can do in these proceeding is to rectify the mistake apparent from the record. In the instant case, what the Assessing Authority .....

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