Addition under Section 69A Cannot Be Made through Rectification Proceedings under Section 154

The Income Tax Appellate Tribunal delivered a significant ruling clarifying the limited scope of rectification powers under Section 154 of the Income-tax Act, 1961.  

The Tribunal held that a fresh addition under Section 69A relating to alleged unexplained cash deposits cannot be introduced through rectification proceedings where the issue requires factual examination, appreciation of evidence, and possible interpretational debate. 

The Tribunal relied upon the landmark Supreme Court judgment in T.S. Balaram v. Volkart Brothers and reiterated that only obvious, patent, and self-evident mistakes can be rectified under Section 154. Since the addition of Rs. 13 lakhs involved detailed factual examination and was not an apparent mistake from record, the rectification order was held to be beyond jurisdiction and was consequently quashed. 

The Tribunal also restored a connected issue involving addition of Rs. 33.10 lakhs under Section 69A back to the Assessing Officer for fresh verification after granting opportunity to the assessee to furnish supporting evidence concerning brick manufacturing business receipts.