2002 (10) TMI 13

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..... fication proceedings were initiated with reference to an issue for which there is more than one view possible and hence it is a debatable issue - question whether disallowance can be made when the amount was not shown in the profit and loss account and further the character of the receipt are also matters on which more than one view is possible – Thus, it cannot be said that there is a mistake app .....

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..... ed in taking recourse to section 154 to make disallowance under section 43B of the sales tax collected by the assessee and was shown as outstanding liability as on March 31, 1984?" The assessment year with which we are concerned is 1984-85. In the original assessment made by the Income-tax Officer, it was found that he did not make any disallowance under section 43B of the Income-tax Act on cert .....

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..... nal found rectification proceedings were initiated with reference to an issue for which there is more than one view possible and hence it is a debatable issue. The question whether disallowance can be made when the amount was not shown in the profit and loss account and further the character of the receipt are also matters on which more than one view is possible. In other words it is the case wher .....

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