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Facts
The assessee filed an updated ITR for AY 2021-22, which was processed by CPC u/s 143(1), raising a demand primarily due to interest u/s 234B. The assessee's rectification request u/s 154 was rejected by CPC. The CIT(A) dismissed the subsequent appeal as non-maintainable, stating the grievance arose from the initial intimation u/s 143(1).
Held
The Tribunal held that a rejection of rectification intimation u/s 154 is an appealable order before the CIT(A). The CIT(A)'s dismissal in limine was incorrect. The Tribunal set aside the CIT(A)'s order and remanded the appeal for fresh adjudication on merits.
Key Issues
Whether an appeal against the rejection of a rectification intimation u/s 154 is maintainable before the CIT(A) and whether dismissal in limine was correct.
Sections Cited
154, 143(1), 234B
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Income Tax Appellate Tribunal, “A” BENCH, CHANDIGARH
Before: HON’BLE SHRI RAJPAL YADAV & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2021- 22 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC dated 15-11-2025 in the matter of a rectification intimation issued by CPC u/s 154 on 09-06-2025. Having heard rival submissions, the appeal is disposed-off as under.
Assessment Year: 2021-22 2. The assessee filed original return of income on 30-06-2021 at Rs.15,17,310/-. However, finding wrong claim of allowances, the assessee filed updated ITR (U) on 28-08-2023 at Rs.19,54,530/- and paid due taxes thereon. This updated return was processed u/s 143(1) on 30-12-2024 wherein CPC raised demand of Rs.1,71,480/- which primarily stem from the fact the CPC charged interest u/s 234B. The assessee sought rectification u/s 154 which stood rejected by CPC on 09-06-2025. Against rejection of rectification as sought by the assessee, the assessee preferred further appeal. The Ld. CIT(A) declared the appeal to be non-maintainable on the ground that the assessee’s grievance arises from intimation as issued by CPC u/s 143(1) on 30-12-2024. Therefore, the appeal was dismissed in limine. Aggrieved the assessee is in further appeal before us.
We find that the sole grievance of the assessee stem from intimation u/s 143(1) qua charging of interest u/s 234B. The assessee preferred rectification route to get his grievance resolved which did not fructify. Left with no option, the assessee preferred further appeal against rejection of rectification intimation. The rejection of intimation u/s 154 is an appealable order before Ld. CIT(A). Therefore, appeal ought to have been adjudicated on the merits only. The dismissal in limine was not correct approach. Therefore, we set aside the impugned order and restore the appeal back to the file of Ld. CIT(A) for fresh adjudication on merits.
The appeal stand allowed for statistical purposes. Order pronounced on 19/02/2026.
Sd/- Sd/- (RAJPAL YADAV) (MANOJ KUMAR AGGARWAL) VICE PRESIDENT ACCOUNTANT MEMBER Dated: 19/02/2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF ASSISTANT REGISTRAR
ITAT CHANDIGARH