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The Commissioner Of Income-Tax, ... vs Shree Man Junathesware, Packing ... on 2 December, 1997

:- 7 -: I.T.A.Nos.1463 & 1464/Mds/2013 "Sec. 154 of the Act opens with the words 'with a view to rectifying any mistake apparent from the record...' The term 'record' as noticed earlier is not defined in the section or in the definition section of the Act. For determining the true scope of this provision and the meaning to be properly assigned to the term 'record' it is necessary to keep in view the object of the provision and the nature of the power conferred on the authorities under that provision. These are the criteria which the Supreme Court adopted while considering the scope and effect of section 263 of the Act and the meaning to be assigned to the word 'record' used in that provision, in the case of CIT Vs. Shree Manjunathesware Packing Products & Camphor Works (1997) 143 CTR (SC) 406 : (1998) 231 ITR 53 (SC). The object with which power is conferred by section 154 is as stated in the marginal heading 'rectification of mistake'. The principal condition for exercising the power under section 154 of the Act is the existence of a mistake in the record. The mistake is not to be a mistake which requires in-depth probing to discover, but is a mistake which is 'apparent' from the record. The power conferred by this provision is only to enable the authorities to rectify the 'apparent' mistakes in the record.
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