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TMI Blog2022 (9) TMI 1146X X X X Extracts X X X X X X X X Extracts X X X X ..... ompany. In the impugned order u/s 154 also the ld AO has mentioned this fact that in the body of the order the fact of amalgamation was mentioned. Thus any error in the title of the order has to be considered to be a mistake apparent from the record and cannot be considered to be anything in the form redetermination of an issue. The fact that the error in mentioning the correct name of the Assessee in the assessment order was one of the ground of appeal pending before the ld CIT(A) does not take away inherent power of Ld. AO to correct the mistakes apparent from the record while exercising powers of section 154. There is no question of opportunity of hearing being required in such case. There is no error in the order of the Ld. AO and th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has been mentioned as M/s Escorts Hospital and Research Centre Limited. Ld. AO observed it to be a inadvertent mistake. He also observed that during the entire course of assessment proceedings, the assessee filed its submissions on the letterhead of M/s Escorts Hospital and Research Centre Limited and the signature in the submissions was also in the name of M/s Escorts Hospital and Research Centre Limited. Ld AO considered it to be a mistake apparent from record and therefore rectified u/s 154 of the Income Tax Act, 1961. Ld CIT(A) 3. Heard and perused the record. 4. On behalf of the Assessee it was submitted that the scope of rectification u/s 154 is limited and the ld AO has tried to undo something which was a ground of appeal pendi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arising out of lack of attention and does not depict in any form that on merits of the case, the said authority has committed any illegality. As such even without any specific provision, every judicial and quasi judicial authority has inherent powers to correct the same. 8. In the case in hand, in the body of the assessment order the Ld.AO has taken cognizance of the fact of amalgamation of the assessee with International Hospital Ltd and that itself is sufficient for the purpose of assessment order indicating that the assessment has been completed keeping in mind the continuity of legal entity of assessee further into amalgamated company. In the impugned order u/s 154 also the ld AO has mentioned this fact that in the body of the order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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