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Section 154 of the Income-tax Act, 1961 - Rectification of mistakes - Apparent from records Question as to whether interest received from deposit made with company/bank, and interest from Income-tax Department are derived from industrial undertaking is debatable issue and same cannot be decided vide rectification proceedings under section 154 [Assessment Years 1991-92 to 1993-94]. In view of the decision in CIT v. Sharp Industries [2006] 282 ITR 336 (Mad.), it was to be held that the question as to whether interest received from deposit made with company/bank, and interest from the Income-tax Department are derived from the industrial undertaking is a debatable issue and the same cannot be decided vide rectification proceedings under section 154. CASE REVIEW CIT v. Sharp Industries[2006] 282 ITR 336 (Mad.)followed & relied upon. JUDGMENT P.D. Dinakaran, J.-The above tax case appeals are directed against the order of the Income-tax Appellate Tribunal in I. T. A. Nos. 2307 to 2309/97 dated August 25, 2004, for the assessment years 1991-92 to 1993-94 respectively, raising the following substantial questions of law. "(a)Whether, on the facts and circumstances of the case, the Tribunal was right in holding that the issue of, whether interest received from deposit made with company/bank, and interest from the Income-tax Department are derived from the industrial undertaking, is debatable issue and the same cannot be decided viderectification proceedings under section 154? (b)Whether, on the facts and circumstances of the case, the Tribunal was right in not following the decision of the Supreme Court in the case of Pandian Chemicals Ltd.v. CIT reported in [2003] 262 ITR 278 the interest from deposits while computing the deduction under section 80HH?" The brief facts that led to the filing of the above appeals…

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