PCIT v. J. J. Glastronics Pvt. Ltd. (2022) 446 ITR 712 (Karn.)(HC)

S. 154 : Rectification of mistake-Book profits-Amounts disallowed under Section 14A cannot be added back to book profits-Debatable issue rectification order is not valid. [S. 14A, 115JB]

Held that amounts disallowed under section 14A cannot be added to the book profits computed under section 115JB. Court also held that the invoking of section 154 would be untenable when there is no mistake apparent on the face of the record, i. e., when the matter requires adjudication upon an issue which is a debatable issue. (AY. 2013-14)