M/S. NATIONAL RUBBER AND CHEMICAL INDUSTRIES,JALANDHAR vs. INCOME TAX OFFICER WARD-1(1), JALANDHAR

ITA 196/ASR/2025Status: DisposedITAT Amritsar31 August 2026AY 2018-193 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal agreed with the CIT(A) that the mistake was apparent from the record and the AO was justified in rectifying the order under Section 154 to recompute tax as per Section 115BBE, given the additions were made under deeming provisions.

What were the facts?

The assessee's assessment was completed with significant additions under Section 68, leading to a high tax demand. The AO later rectified this order under Section 154 to invoke Section 115BBE, further increasing the demand. The assessee appealed the rectification order, but the CIT(A) dismissed it on merits.

What were the issues?

Whether the AO was justified in rectifying the assessment order under Section 154 to invoke Section 115BBE for additions made under Section 68. Whether the CIT(A) correctly dismissed the appeal on merits.

Which sections of the Income-tax Act were involved?

Section 68,Section 154,Section 115BBE,Section 250,Section 249(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. S. RIFAUR RAHMAN & SH. UDAYAN DAS GUPTA

Hearing: 22.07.2026Pronounced: 31.08.2026

Per: Udayan Dasgupta, JM: This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the IT Act, 1961, dated 30.12.2024, which has emanated from the order of the AO, passed u/s 154 of the Act, dated 08.10.2021. 2. Condonation of Delay: This appeal is filed belatedly by three days. Considering the reasons stated by the Ld AR of the assessee, the delay of only three days are condoned and appeal is admitted for hearing on merits.

3.

The assessee has filed an elaborate statement of facts and has taken nine grounds in form 36 , which is in essay form ( not in confirmation of ITAT Rules’63), and the main grievance is against the Ld first appellate authority

The order continues below.

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