#mistake apparent from record

ITAT Kolkata has ruled that errors in an income tax return - such as incorrect LTCG computation - can be corrected under Section 154 if apparent from the record, regardless of whether the rectification changes the total income. This affirms that the scope of rectification extends to the return itself, not just assessment orders, reinforcing natural justice and the tax officer’s duty to ensure accurate computation under CBDT Circular 14/1955.

The ITAT Delhi has firmly held that Section 254(2) of the Income Tax Act permits correction of clerical or obvious mistakes only, and cannot be used to re-evaluate factual or legal merits already decided. This reinforces the finality of tribunal orders and prevents parties from using rectification as a backdoor appeal, directly impacting tax litigants and revenue authorities seeking to reopen concluded cases.