S. 154 : Rectification of mistake-Mistake apparent from the record-Inadvertently disclosed income in its return-Return was accepted u/s. 139(1)-Rectification is rejected-Tribunal allowing the claim-Dismissing the appeal the Court held that merely because respondent included the income in the return as taxable cannot make it amenable to imposition of tax-DTAA-India-USA [. S. 139(1),143(1), 260A, Art. 14]
CIT (IT) v. Heidrick and Struggles Inc. (2024) 461ITR 33 (Delhi)(HC) Editorial : Followed CBDT Circular 14 of 1995 dated 11.04.1995. Referred CIT v. Bharat General Reinsurance Co. Ltd. (1971)81 ITR 303 (Delhi)(HC)