It was held that the rectification petition filed by the assessee under section 154 of the Act was on a debatable issue and therefore, it could not be considered at this stage. That apart, the assessee had submitted that the issue was pending before the High Court. Thus, there was no infirmity in the order passed by the Commissioner (Appeals).(AY. 2009-10)
Periyasamy Pillai Educational Trust v. ITO(E) (2022) 96 ITR 70 (SN.) (Chennai)(Trib)
S. 154 : Rectification of mistake-Mistake apparent from the record-Charitable Purpose-Taxability of corpus donations-Issue pending in High Court-Debatable issue-Rectification is not permissible. [S. 11(1(d), 12AA]