GANPATRAO MIRJE FAMILY TRUST,KOLHAPUR vs. INCOME TAX OFFICER WARD 2(1), KOLHAPUR

ITA 3346/PUN/2025Status: DisposedITAT Pune16 June 2026AY 2013-1410 pages
AI SummaryDismissed

What were the facts?

The assessee trust filed a rectification application under Section 154 of the Income Tax Act, 1961, to correct an error in its total income computation. The application was filed beyond the statutory time limit of 4 years.

What did the Tribunal hold?

The Tribunal held that the provisions of Section 154(7) of the Act are clear and unambiguous, prescribing a strict 4-year time limit for rectification. Since the application was filed beyond this period, it was rightly dismissed by the lower authorities.

What were the issues?

Whether a rectification application filed beyond the statutory time limit of 4 years under Section 154(7) can be entertained by the Income Tax authorities.

Which sections of the Income-tax Act were involved?

Section 154,Section 154(7)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & Ms. ASTHA CHANDRA

For Appellant: Shri Vaibhav R Chaugule
For Respondent: Shri Rajesh Gawali, Addl. CIT DR

PER R.K. PANDA, VP:

The above batch of 4 appeals filed by the assessee are directed against the separate orders dated 31.10.2025 of the Ld. Addl / JCIT(A)-1, Chandigarh relating to assessment years 2012-13 to 2015-16 respectively. Since identical grounds have been raised in all these appeals, therefore, these appeals were heard together and are being disposed of by this common order for the sake of convenience.

2.

Facts of the case, in brief, are that the assessee filed a rectification application on 16.07.2024 regarding the erroneous computation of total income u/s 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for assessment year 2012-13. The Assessi

The order continues below.

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