We find that in the facts and circumstances of the, present case, the mistake apparent on the face of record sought to be rectified under s. 154 of the Act was not maintainable as for establishing the same, a long drawn process of reasoning on points after examining the true nature of expenditure needs to be carried out. Thus, in order to ascertain the correct and true nature of expenses relatable to the documents reflected in the books of account, the issues have been re-examined and from, rectification have travelled to a Revenue of the order which is not permissible. Thus, the order passed by the AO is beyond the compass of mistake/error apparent on the face of the record. Accordingly, we find that the appeal of the Revenue has to be dismissed. Addressing the decision relied upon by the learned Authorised Representative for levy of costs upon the Revenue for having filed the appeal, we find that the principle of law as set-out in the aforesaid decision of the Hon'ble High Court in the case of assessee itself has been wrongly invoked in the facts of the present case. The filing of the present appeal cannot be said to be frivolous exercise of power by the AO even if ultimately the appeal has been dismissed by us on merits. The decision rendered by the jurisdictional High Court in assessee's case is fact specific and has no relevance and applicability on the issues on the basis of facts on record. Accordingly, cross-objection of the assessee is also dismissed.