GITCO TRADERS PRIVATE LIMITED,MUMBAI vs. ITO - 3(1)(3), MUMBAI

ITA 1567/MUM/2026Status: DisposedITAT Mumbai25 May 2026AY 2009-1010 pages
AI SummaryDismissed

What were the facts?

The assessee filed its return of income for AY 2009-10 declaring a total income. Subsequently, after nearly nine years, it filed a rectification application under section 154, claiming errors in its original computation and seeking a refund. The Assessing Officer and the first appellate authority rejected this application.

What did the Tribunal hold?

The Tribunal held that section 154 is for rectifying apparent mistakes and not for rewriting the original return or making fresh claims. The assessee's application was filed beyond the limitation period and sought substantial recomputation, which is outside the scope of section 154.

What were the issues?

Whether a rectification application filed after a significant delay can be used to correct errors in the assessee's own computation of income and make fresh claims, and whether such claims fall within the scope of section 154.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(1),Section 154(7),Section 244A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘G’ BENCH

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL&

For Appellant: Shri Rajiv Khandelwal, Ms. Jigna Jain-Advocate
For Respondent: Shri Pradipsinh Saktavat
Hearing: 26/02/2026Pronounced: 25/05/2026

PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against the order dated 17.11.2025 passed by the learned

2 ITA No.1567/Mum/2027 & SA No.33/Mum/2026 Gitco Traders Pvt. Ltd., Addl./JCIT(A), Panchkula, arising out of the order passed by the Assessing Officer under section 154 of the Income Tax Act, 1961 for Assessment Year 2009-10, whereby the Assessing Officer had rejected the rectification application filed by the assessee and the said action has been upheld by the learned first appellate authority. The assessee is primarily aggrieved by the rejec

The order continues below.

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