Munjal Showa Ltd. vs Deputy Commissioner Of Income Tax on 7 September, 2000
10. A mistake apparent on the record must be an obvious and patent mistake and not something which can be established by a long drawn process of reasoning on points on which there may be conceivably two opinions. A decision on a debatable point of law is not a mistake apparent from record. This view finds support from various decisions including the decisions in (1971) 82 ITR 50 (SC) (supra), CIT vs. Calcutta Steel Co. Ltd. (1988) 174 ITR 521 (Cal), CIT vs. K. Subnani Construction Co. Ltd. (1989) 177 ITR 219 (Bom), Sagar Co-op, Central Bank Ltd. vs. CIT (1985) 186 ITR 292 (MP) and CED vs. Hari Bux Poddar (Decd.) (1990) 182 ITR 423 (Pat).