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The assessee in this appeal is aggrieved by the action of the Assessing Officer which is further confirmed by the CIT(A) in denying deduction claimed by the assessee u/s 54B of the Income-tax Act by way of rectification order passed u/s 154 of the Income-tax Act, 1961.

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Section 54B & 154 of the Income-tax Act, 1961—Rectification of mistake - In the case of a debatable issue or where the lengthy arguments are needed to decide the issue, powers u/s 154 can not be exercised to amend an already passed order and It has also been held time and again that powers u/s 154 cannot be exercised on change of opinion by the Assessing Officer on an issue relating to any admissibility of a claim, therefore, the Assessing Officer was not justified in passing the impugned order u/s 154 with limited jurisdiction of rectification of order in the case of a 'mistake apparent on record' in the order. - SANDEEP BHARGAV V/s DY. CIT - [2020] 183 ITD 437 (ITAT-CHANDIGARH)

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