This section is a neutral provision, neither revenue friendly unlike section 263 nor assessee friendly unlike section 264 of the Act. But it has limited application, since it is bound by the wording of "Mistake apparent from records"
Section 264 of the Income Tax Act provides, Powers to the Commissioner of Income Tax (CIT) to exercise the order in favour of the assessee.
This artice covers the meaning of Actual Payment under Section 43B of Income-tax act 1961
Section 151 of the Income Tax Act 1961(Act), provides that Assessing officer (AO) has to take approval from the higher authority before issuing the notice u/s 148. AO, by the provisions of section 147 of the Act, has the power, to reopen the already completed Assessment.