Allowing the appeal the Tribunal held that  the assessee had filed the return of income in a negligent and casual manner with errors and omissions. Moreover, income chargeable to tax at a special rate has been reported as nil in both columns, i. e., as provided by the taxpayer as well as computed under section 143(1) of the Act. Despite nil income having been reported in both columns, against serial No. 10, the Assessing Officer in serial No. 22 has computed tax at special rate in both columns for taxpayer as well as under section 143(1) of the Act. Thus, there was an apparent mistake in computing the tax at a special rate without any income having been reported for tax at a special rate. The assessee was at fault for not reporting the income in the proper columns, but the Assessing Officer had also committed apparent mistakes of computing tax without considering the income for special rate. The order of the Commissioner (Appeals) was to be set aside and the matter restored to the Assessing Officer for deciding the rectification application of the assessee on the merits keeping in view the cardinal principle that the assessee cannot be taxed twice for the same income, one under the head “Profits and gains of business and profession” and other under “Special rate specified in DTAA”. (AY.2014-15)