Tribunal held that the Assessing Officer had not doubted the genuineness of the transaction. Therefore, the proceedings under section 154 of the Act were taken on a mere change of opinion, which was outside the mandate of the section. A mistake apparent on the record must be an obvious and patent mistake and not something which could be established by a long-drawn process of reasoning on points on which there might conceivably be two opinions. Since the assessee had proved that there was commercial/business expediency in making cash purchases, the mistake could not be obvious and apparent from record. Accordingly disallowance was deleted. (AY.2014-15)