Rectification post facto Apex court decision within time limit under section 154 - validity

Facts:

Assessee's rectification petition based on a subsequent Apex court decision was rejected by lower authorities citing that an Apex court decision was not a 'mistake apparent on record' amenable to section 154. On higher appeal -

Held in favour of the assessee that CBDT circular no. 68 dtd 17-11-1971 confirms that a rectification arising out of a subsequent court decision is a mistake apparent on record as long as it is filed within the time limit under section 154.

Case: Sudiva Spinners (P) Ltd. v. ACIT 2024 TaxPub(DT) 383 (Jod-Trib)