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“mistake apparent from record”

Rectification & RevisionSection 154Section 154700 judgments

The decision most relied on for mistake apparent from record is Kourani v. Union OF India (83 Taxmann.com 137), cited in 1,708 judgments on BharatTax.

Leading authorities on mistake apparent from record

Kourani v. Union OF India
83 Taxmann.com 137 · 2017 · High Court
1,708
citing judgments

The fee under Section 234E for late filing of TDS/TCS statements cannot be levied retrospectively by processing an intimation under Section 200A for defaults occurring before the amendment allowing such processing.

ACIT v. Saurashtra Kutch Stock Exchange Ltd.
305 ITR 227 · 2008 · Supreme Court
470
citing judgments

Non-consideration of a decision by a jurisdictional High Court or the Supreme Court constitutes a mistake apparent from the record. However, non-consideration of a non-jurisdictional High Court decision does not typically amount to such a mistake.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Hero Cycles (P.) Ltd.
228 ITR 463 · 1997 · Supreme Court
262
citing judgments

A point not examined on facts or in law cannot be treated as a mistake apparent on record for rectification purposes.

DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation
330 ITR 578 · 2011 · High Court
115
citing judgments

Interest under Section 234B is generally not leviable on non-residents whose income is subject to tax deduction at source under Section 195, provided the non-resident assessee did not induce short or non-deduction of TDS by the payer.

CIT v. Aruna Luthra
252 ITR 76 · 2001 · High Court
87
citing judgments

Rectification under Section 154 is permissible based on a subsequent judgment of the Jurisdictional High Court or the Supreme Court. Such a judgment clarifies the law as it always stood, thereby revealing a mistake apparent from the record.

Addl. CIT v. J.K. D'Costa
133 ITR 7 · 1982 · High Court
57
citing judgments

Debatable issues cannot be rectified under Section 154 of the Income-tax Act, as rectification is limited to mistakes apparent from the record.

Mepco Industries Ltd. v. CIT
319 ITR 208 · 2009 · Supreme Court
50
citing judgments

A mistake rectifiable under Section 154 must be obvious and apparent from the record, not one that requires a long process of reasoning or constitutes a mere change of opinion.

Judgments citing mistake apparent from record

DCIT, Circle-3, Thane vs. Jaimuni Sahakari Patpedhi Maryadit, Vasai

In the result the appeal filed by the revenue stands dismissed

ITA 990/MUM/2025[2017]Status: DisposedITAT Mumbai30 Apr 2025

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(2)Section 69ASection 80

operative banks during the period of demonetization period amounting to Rs. 94,18,271 as unexplained money. Its a prima facie mistake apparent from records which shows that the amount of addition of total cash in odd figures i.e. if the deposit in SBNs are in the notes

Ambekar Beverage and Food Private Limited, Mumbai vs. ITO Ward 6(1)(2), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1655/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Apr 2025AY 2015-16

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhriआयकर अपील सं./Ita No. 1655/Mum/2025 (निर्धारण वर्ा / Assessment Year :2015-16) Ambekar Beverages & V/S. Ito 6(1)(2), Mumbai Food Pvt. Ltd. बिधम Aayakar Bhavan, M.K. 129, 5Th Floor, 501-502, Road, Mumbai-400020 Shree Krupa, M. B. Raut Road, Shivaji Park, Dadar West, Mumbai, Maharashtra-400028 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aakca7151R Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Shekhar L. Gajbhiye
Section 144Section 154Section 234ASection 250Section 271(1)(b)Section 68

facts and circumstances of the case and in law the additions should have been Rs.38,21,438/- (i.e, 7394202-3572764). This is a mistake apparent from record for which rectification u/s. 154 shall be filed by the Appellant. 4. In the facts and circumstances of the case

Milagro Ceremica Private Limited, Mumbai vs. Circle 15(2)(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1033/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Apr 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Parth Bhatt, CAFor Respondent: Shri R. R. Makwana, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 154Section 156

Milagro Ceremica Pvt. Ltd. A.Y. 2018-19 disposal of application filed u/s.154 whereby assessee was under bonafide belief that it is a mistake apparent from record which would not require taking up the matter under litigation. Since there was prolonged delay and matter remained pending, assessee chose to file appeal

Robossist Technologies, Pune vs. Ward 1, ITO, Ahmednagar

In the result, appeal of the assessee is allowed for statistical purposes

ITA 507/PUN/2025[2019-2020]Status: DisposedITAT Pune28 Apr 2025AY 2019-2020

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No. 507/Pun/2025 धििाारण वषा / Assessment Year: 2019-20 Vs Ito Ward-1, Robossist Technologies, D302, 202, Sky Ahmednagar Belvedere, New Airport Road, Pune-411032 Maharashtra Pan-Aapfr6267D Appellant Respondent

For Appellant: Shri Pramod ShingteFor Respondent: Shri Ganesh B
Section 143Section 143(1)Section 143(1)(A)Section 143(1)(a)Section 154Section 250Section 500Section 50C

stating that provision of section 50C are not applicable. Ld. AO allowed the assessee’s application u/s 154 stating that there was a mistake apparent from record in the order u/s 143(1)(a) of the Act. Subsequently Ld. AO again passed an order

Veetraag Vani Trust Regsd, Tikamgarh vs. ITO, Exemption Ward, Gwalior

The appeal stand dismissed

ITA 31/AGR/2023[ 2014-15]Status: DisposedITAT Agra22 Apr 2025

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.31/Agr/2023 (िनधा"रणवष" / Assessment Year: 2014-15) Veetraag Vani Trust Income-Tax Officer (Exemption) बनाम/ Sahil Sagar Chauraha Ward- Gwalior. Near Arihant Public School, Vs. Tikamgarh (Mp). "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-6832-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Rajendra Sharma, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of An Order Passed By Of Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] On 28-12-2022 In The Matter Of An Rectification Order Passed By Ld. Ao U/S 154 On 18-12-2020. It Emerges That The Assessee Filed Return Of Income At Rs.20.79 Lacs Which Was Accepted U/S 143(1). The Assessee Revised Return Of Income On 28-02- 2016 Claiming Exemption U/S 10(23)(Iiiad) Followed By Rectification Which Was Rejected On The Ground That There Was No Mistake Apparent From Record. The Rectification Order Was Under Challenge Before Ld. Cit(A). In Para 9.7 Of Impugned Order, Ld. Cit(A) Confirmed The Rectification Order On The Ground That The Fresh Claim So Made By The Assessee Was Beyond

For Appellant: Sh. Rajendra Sharma, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. Sr. DR
Section 10(23)(iiiad)Section 143(1)Section 154

claiming exemption u/s 10(23)(iiiad) followed by rectification which was rejected on the ground that there was no mistake apparent from record. The rectification order was under challenge before Ld. CIT(A). In para 9.7 of impugned order, Ld. CIT(A) confirmed the rectification order on the ground that ... claim was not there in the original return of income. Therefore, it could not be said that there was mistake apparent from record. Aggrieved, the assessee is in further appeal before us. 2. It is quite clear that the impugned claim was not made by the assessee in the original

Adhere Foundation, Pune vs. AO, Exemption Ward, Pune

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 954/PUN/2024[AY 2021-22]Status: DisposedITAT Pune22 Apr 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.954/Pun/2024 Assessment Year : 2021-22

For Appellant: Shri Sushil VarmaFor Respondent: Shri Ramnath P. Murkunde
Section 11Section 12ASection 143(1)Section 154Section 250Section 8

arisen at the stage of 143(1), the issue cannot be adjudicated upon in the present appeal and further there is no mistake apparent from record at the stage of 154. Therefore, the grounds of appeal are dismissed. 5. In the result, appeal is dismissed.” 8. Now the assessee

Asst. Commissioner of Income Tax, Panvel vs. Flowline Systems Pvt Ltd, New Panvel

In the result, appeal of the Revenue is dismissed

ITA 2168/PUN/2024[2021-22]Status: DisposedITAT Pune17 Apr 2025AY 2021-22

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2168/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Assistant Commissioner V Flowline Systems Pvt. Ltd., Of Income Tax, S 401, 402, Bhoomi Landmark, Panvel. New Panvel, Dist-Raigad. Maharashtra – 410206. Pan: Aabcf1096R Appellant / Revenue Respondent / Assessee Assessee By Shri A R Sakhalkar & Shri M.R.Dharmadhikari –Ar’S Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 20/03/2025 Date Of Pronouncement 17/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 14.08.2024 For A.Y.2021-22 Emanating From Order Under Section 154 Of The Income Tax Act, 1961 Issued By Adit(Cpc), Bangalore. The Revenue Has Raised The Following Grounds Of Appeal :

Section 154Section 250Section 250(4)Section 46A(3)

first place, The Ld. CIT(A), NFAC was fully convinced and satisfied in arriving at a conclusion that the said addition is a mistake apparent from records. Thus, he did not find any reasons or necessity to make any further inquiry and he did not deem it a fit case

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1279/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Apr 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132(1)Section 139Section 143(3)Section 153ASection 154Section 270A

fact taxable income. The revised return can be at best be treated as retraction from the earlier return and there is no mistake apparent from record. The ITAT has given the decision considering peculiar facts of the case as mentioned in the order, which cannot be applied in each case

Sinuj Vijayan, Vadakkencherry vs. ITO, Ward2, Palakkad

In the result, the appeal filed by the assessee stands allowed

ITA 806/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Sinuj Vijayan .......... Appellant Vijay Steels, Bus-Stand, Vadakkencherry Palakkad 678683 [Pan: Asnpv3671K] Vs. The Income Tax Officer, Ward-2 .......... Respondent Aayakar Bhavan, English Chruch Road Palakkad 678001

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 154

There is no material on record to suggest that the amount of rent payable calls for addition. I do not find any mistake apparent from record which is being capable of being rectified u/s. 154 of the Act. Therefore, the AO ought not have exercised jurisdiction

Nagar Urban Co-Op Bank Ltd, Ahmednagar vs. Deputy Commissioner of Income Tax, Ahmednagar Circle, Ahmednagar

In the result, the appeal of the assessee is allowed

ITA 208/PUN/2024[2012-13]Status: DisposedITAT Pune08 Apr 2025AY 2012-13

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Ramnath P. Murkunde
Section 143(3)Section 41(1)

achieve through the additional grounds of appeal no. 2 and 3, and that the rectification application was rejected as there was no mistake apparent from record. Having tried all possible remedies before the assessing authority, the appellant raised the two additional grounds in question during the appellate proceedings

Dy Commissioner of Income Tax, Central Circle-1(4), Mumbai vs. Ultratech Cement Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 821/MUM/2025[2011-12]Status: DisposedITAT Mumbai08 Apr 2025AY 2011-12

Bench: Shri Saktijit Dey & Shri Prabhash Shankar

Section 139Section 143(3)Section 154Section 801ASection 80I

ground raised by the assessee that a (as alleged) change of opinion on the same set of facts is not a mistake apparent from record when the impugned matter of the claim of deduction u/s.801A(12A) of the Income Tax Act, 1961 is a direct beneficial claim the wrong allowability ... deduction u/s 80IA in respect of seven units transferred after 01.10.2009 from the demerged company. The assessee argued that there was no mistake apparent from records necessitating rectification of order passed u/s 143(3) of the Act. The INCOME TAX APPELLATE TRIBUNAL Page | 4 ITA No. 821/Mum/2025

Dombivali Nagari Sahakari Bank Ltd, Dombivali vs. Income Tax Officer, Ward 3(1), Kalyan

In the result, appeal by the assessee is allowed

ITA 6089/MUM/2024[2021-22]Status: DisposedITAT Mumbai08 Apr 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Ms. Tejaswi S. Pendse, CAFor Respondent: Smt. Sanyogita Nagpal, CIT DR
Section 143(1)Section 154Section 36(1)Section 36(1)(viia)Section 41

dated 01.12.2022 whereby total income was computed at Rs.52,26,55,570/-. Against this intimation, assessee filed an application for rectification of mistake apparent from record u/s.154 on 19.01.2023. Pending this application, assessee preferred an appeal before ld. CIT(A), challenging the adjustment made u/s. 143(1) which ... Counsel of the assessee at the outset pointed out that subsequently CPC, Bengaluru has passed an order u/s.154 dated 06.07.2023 whereby the mistake apparent from record has been rectified accepting the claim of the assessee, thereby total income reported in the return was accepted. Copy of the said order

ACIT, Circle, Panchkula vs. M/S Haryana State Industrial & Infrastructure Dev. Corp. Ltd., Panchkula

In the result, appeal of the Revenue is dismissed

ITA 1424/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh07 Apr 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri A.K. Jindal and Ms. Rattan Kaur, C.A’sFor Respondent: Shri Rohit Sharma, CIT DR
Section 14ASection 28

where the same has been admitted by the Coordinate Bench and adjudicated upon, we find that there is no mistake apparent from record and any action can be contemplated or sought within the provisions of section 254(2) of the Act. Infact, the assessee has availed the remedy as available

Claqyx Securities P.Ltd, New Delhi vs. ITO, Ward-6(2), New Delhi

ITA 1520/DEL/2019[2012-13]Status: DisposedITAT Delhi07 Apr 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaita No.1517/Del/2023 (Assessment Year 2015-16)

Section 143(1)Section 154Section 250

this Tribunal, however, vide order dated 27.11.2020, the rectification application was dismissed by the Assessing Officer by observing that there is no mistake apparent from record and the same has been sustained by the Ld. CIT(A), for which assessee is in appeal. Phool Singh vs. ITO 4. After going

The Tatta Niwashi Co Operative Housing Society Ltd, Mumbai vs. ITO Ward 27(3)(1), Mumbai

In the result appeal filed by the assessee stands allowed for statistical purposes

ITA 756/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Apr 2025AY 2019-20

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(1)Section 143(1)(a)Section 154

view that the right of the assessee could not be denied merely on accounting of technical errors. Hence there is a mistake apparent from record in not granting exemption claimed by the assessee. Accordingly, I am of the view that the said mistake deserves to be rectified.” 7 I.T.A. No.756/Mum/2025

Adopt Commotrade Private Limited Through Shivalik Engineering Industries Limited, Raipur vs. Dy Commissioner of Income Tax, Circle 1(1), Raipur

In the result, appeal of the assessee company is allowed for statistical purposes

ITA 499/RPR/2024[2023-24]Status: DisposedITAT Raipur02 Apr 2025AY 2023-24

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.499/Rpr/2024 "नधा"रण वष" / Assessment Year : 2023-24 Adopt Commotrade Private Limited Though Shivalik Engineering Industries Limited Flat No. C-33, Ring Road No.1, Ashoka Millenium, Rajendra Nagar, Pan: Aadcv5964C

For Appellant: S/shri Praveen Khandelwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 154

raised a fresh/additional claim which was not there in the original return of income, therefore, the same could not be considered as mistake apparent from record. 4. Aggrieved the assessee company carried the matter in appeal before the Ld. CIT(Appeals) who after considering the submissions of the assessee company ... Circle-1, Raipur needs to be considered while framing the assessment and in this case, since it was not done, thus, it was mistake apparent from record and for that reason, the rectification application u/s.154 of the Act was filed. However, prayer before the Tribunal was that in this backdrop

Ramdas Singh Tomar, Rajasthan vs. Income Tax Officer, Ward 1(1), Jaipur

ITA 1092/JPR/2024[2018-19]Status: DisposedITAT Jaipur01 Apr 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1092/JP/2024 निर्धारण वर्ष / Assessment Year : 2018-19 Ramdas Singh Tomar M/s Om Sai Construction, Harikand Ka Pura Faraspura, Dholpur बनाम Income Tax Officer, Ward 1(1), Jaipur स्थायीलेखा सं. / जीआईआर सं./PAN/GIR No.: AMZPT4728R अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Rahul Pandya, Adv. राजस्व की ओर से / Revenue by: Sh. Anup Singh, Addl. CIT सुनवा

For Appellant: Sh. Rahul Pandya, AdvFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115BSection 139(1)Section 142(1)Section 147Section 148Section 148ASection 2Section 271ASection 69A

performance incentive had been assessed for assessment year 2008-09, assessment of same amount for impugned assessment year 2007-08 was a mistake apparent from records - Held, yes - Whether, therefore, assessee's claim was to be allowed - Held, yes [In favour of assessee]” That the Hon’ble HIGH COURT

Ajay Kumar, Lucknow vs. Income Tax Officer-3(1), Lucknow

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 11/LKW/2023[2011-12]Status: DisposedITAT Lucknow28 Mar 2025AY 2011-12

Bench: Shri Kul Bharat & Shri Nikhil Choudharyassessment Year: 2011-12 Ajay Kumar Income Tax Office-3(1) V. 44/6, Jankipuram Extention, Pratyakshkar Bhawan, Near Dronacharya Academy, 57, Ram Teerath Marg, Lucknow-226021. Lucknow-226001. Pan: Asupk4666L (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 20 03 2025 Date Of Pronouncement: 28 03 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 144Section 147Section 148Section 154

made without issue of notice u/s 148. This ground was a part of my first ground before CIT(A). iii. There was no mistake apparent from record in passing original order u/s 147/144 dated 28.12.2018 because all points recorded in reason of u/s 147 was considered by AO. The reasons

Mandke Foundation, Mumbai vs. ACIT Exemption-2, Mumbai

In the result, the appeal of the assessee is allowed

ITA 329/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Mar 2025AY 2017-18

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सं./Ita No. 329/Mum/2025 (निर्धारण वर्ा / Assessment Year :2017-18) Mandke Foundation V/S. Acit Exemptions-2, Plot No. 141, A Four बनाम Mumbai Bunglows, Rao Saheb Room No. 608, 6Th Floor, Achyutrao Patwardhan Cumbala Hill, Mtnl Telli Marg, Andheri West, Phone Exchange Building, Maharashtra-400053 Pedder Road, Maharashtra-400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaatm4557G Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Jitendra SanghaviFor Respondent: Shri R. R. Makwana
Section 11Section 11(1)(a)Section 13(3)Section 154Section 234Section 234DSection 250

adding the application of income amounting to Rs. 6,90,226 as income and not reducing the expenditure eligible for application is a mistake apparent from records and the same ought to be reduced (B) CHARGING OF INTEREST U/S. 234D OF THE ACT 3 On the facts and circumstances

Arif Munir, Kanpur vs. Income Tax Officer-(2)(1)(2), Kanpur

In the result, the appeal of the assessee stands allowed

ITA 6/LKW/2025[2017-18]Status: DisposedITAT Lucknow24 Mar 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Arif Munir V. The Ito(2)(1)(2) 13/397, Vip Road Kanpur Near Green Park Civil Lines, Kanpur Tan/Pan:Afjpm1226J (Appellant) (Respondent) Appellant By: Shri Pranendra Mirdha, Advocate Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 18 03 2025 Date Of Pronouncement: 24 03 2025 O R D E R This Appeal Has Been Preferred By The Assessee Against Order Dated 28.02.2024, Passed By The Addl/Jcit(A)-1, Kolkata For Assessment Year 2013-14. 2. The Brief Facts Of The Case Are That The Assessee E-Filed His Return Of Income For The Year Under Consideration On 30.07.2017, Declaring A Total Income Of Rs.5,92,280/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass. During The Course Of Assessment Proceedings, In Response To The Queries Raised By The Assessing Officer (Ao), The Submission On Behalf Of The Assessee Was That Rs.2,44,000/- Was Deposited In His Bank Account Maintained With Hdfc Bank Limited Out Of His & His Wife’S Past Savings. Not Being Satisfied With The Reply Furnished

For Appellant: Shri Pranendra Mirdha, AdvocateFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 115BSection 143(3)Section 154Section 271ASection 69ASection 80C

mind stating that authority has no power to review its own while in the whole rectification application the prayer was only rectify the mistake apparent from record not of review. F. Because the rectification application was only eliminate the error. The Hon'ble High Court in, Blue Star Engineering ... impugned order of the Addl/JCIT(A)-1, Kolkata was received by the assessee on 28.02.2024. However, the assessee, presuming that there are some mistakes apparent from record in the order of the Addl/JCIT(A)-1, Kolkata, filed a rectification application on 03.04.2024 under section