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Whether on the facts and circumstances ofcase& in law, the ld. CIT (A) has erred in holding that AO has charged his opinion and impugned order is beyond the scope of section 154.

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Sec. 154 of Income Tax Act, 1961— Rectification of Mistake— Assessing Officer has taken into consideration the material and the outcome of the enquiries received subsequent to conclusion of the assessment proceedings, hence, it cannot be held that the action of the Assessing Officer of rectifying the mistake do not emanate from the record of the Assessing Officer available at the time of assessment, ergo, it cannot be held to be a mistake apparent from the record rectifiable u/s 154 - DEPUTY CIT V/s GULSHAN CHEMICALS LTD. - [2020] 184 ITD 071 (ITAT-DELHI)

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