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“mistake apparent on record”

Rectification & RevisionSection 154Section 154888 judgments

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

Leading authorities on mistake apparent on 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 on record

Mammunhi Mohammed Abdurrahiman Talangara, Mumbai vs. ITO-19(2)(2), Mumbai

ITA 848/MUM/2024[2017-18]Status: DisposedITAT Mumbai15 Jul 2024AY 2017-18

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Gautam Varun BramhechaFor Respondent: Shri Himanshu Sharma (CIT DR)
Section 143(1)Section 154Section 37Section 37(1)

Representative relied upon the order passed by the CIT(A) and submitted that in view of the tax audit report, there was no mistake apparent on record and therefore, no fault could be found in the order passed by the CIT(A). 6. On perusal of material placed on record

Bosch Rexroth (India) Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

In the result, the appeal of the Assessee is allowed

ITA 930/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.930/Ahd/2015 "नधा"रण वष" /Assessment Year : 2010-11 Bosch Rexroth (India) Ltd. The Income Tax Officer बनाम/ Near Village Iyava Ward-1(1)(3) Sanand Viramgam Highway Ahmedabad V/S. Tal: Sanand Dist: Ahmedabad – 382 170 "थायी लेखा सं./Pan: Aaacm 9898 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar Revenue By : Shri Samir Tekriwal, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 04/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: The Captioned Appeal Preferred By The Assessee Is Against The Order Of The Assessing Officer, Ahmedabad Relating To Assessment Year 2010-11 Passed Under Section 143(3) R.W.S.143C(5) Of The Income-Tax Act, 1961 (In Short “The Act) Order Dated 12/12/2015 Passed In Pursuance Of Directions Of The Dispute Resolution Panel (In Short “Drp”) Under Section 144C(5) Of The Act Dated 10/12/2014. Bosch Rexroth India Ltd. Vs. Ito Asst. Year : 2010-11

For Appellant: Shri S.N. Soparkar, Sr.Advocate and Shri Parin Shah, ARFor Respondent: Shri Samir Tekriwal, CIT-DR
Section 143(3)Section 144C(5)

finding of the Tribunal for the impugned year is contrary to its earlier decision on the similar issue. Therefore, this being a mistake apparent on record of the case and the Tribunal found merit in the contention of the assessee decided to reconsider the issue and decided to recall

ITO-6(1), Lucknow vs. M/S U.P. State Mineral Development Corporation Ltd., Lucknow

ITA 261/LKW/2020[2007-08]Status: DisposedITAT Lucknow04 Jul 2024AY 2007-08

Bench: Hon’Ble Shri G. D. Padmahshali & Shri Subhash Malguriaआयकर अपील सं. / Ita No.261/Lkw/2020 निर्धारण वर्ा / Assessment Year : 2007-08 The Income Tax Officer Ward-6(1), Lucknow . . . . . . . अपीलार्थी / Appellant

For Appellant: None for the AssesseeFor Respondent: Smt. Namita Pandey [‘Ld. DR’]
Section 143(2)Section 154Section 250

addition of Rs. 70.95,000/- made by the A.O. without appreciating the fact that mistake pointed out by the RAP is a mistake apparent from record as the provision for loss in investments was not allowable and the same was rightly disallowed us 154 of the Income ... disallowance of ‘provision’ is not a debatable issue and not disallowing such provision for loss in investment while assessing the income is a mistake apparent on record hence is rectifiable u/s 154 of the Act. The present challenge thus seeks to answer twin questions viz; (1) as to whether disallowance

Haldiram Foods International Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Bengluru

In the result, the appeal is allowed for statistical purpose

ITA 1350/MUM/2024[2022-2023]Status: DisposedITAT Mumbai27 Jun 2024AY 2022-2023

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: Shri Yogesh Thar, A.RFor Respondent: Shri P. D. Chougule, (Addl. CIT), SR. D.R
Section 115BSection 143(1)Section 154Section 250Section 43B

failed to appreciate that the omission in disclosure in the tax audit report regarding payment of gratuity is a mistake apparent on record leading to adjustment in the intimation u/s. 143(1) and therefore the same is liable for rectification u/s. 154 and therefore the grounds emanated from the rectification ... order declining to rectify the mistake apparent on records. 1.3. The Appellant prays that the order passed u/s 250 declining to decide the grounds arising from the rectification order be quashed. WITHOUT PREJUDICE TO GROUND NO 1; GROUND NO. 2: DISALLOWANCE OF PAYMENT MADE TO GRATUITY FUND AMOUNTING

Mukta A2 Cinemas Limited, Mumbai vs. Income Tax Officer, Central Processing Centre-Bengaluru, Mumbai

In the result, the appeal filed by the assessee is accordingly

ITA 1453/MUM/2024[2020-21]Status: DisposedITAT Mumbai18 Jun 2024AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

For Appellant: Mr. Ankush Kapoor, CIT-DRFor Respondent: Mr. Dharmesh Shah
Section 154

appreciating that there is a mistake apparent on ut appreciating that there is a mistake apparent on ut appreciating that there is a mistake apparent on record resulting in double addition of income of Rs. record resulting in double addition of income of Rs. record resulting in double addition ... stating that an application for rectification rejected by the AO CPC stating that an application for rectification can be filed only to correct mistakes apparent from records. In can be filed only to correct mistakes apparent from records. In can be filed only to correct mistakes apparent from records

Everest Business Advisory India P.Ltd, Gurgaon vs. ACIT, Circle-7(1), New Delhi

ITA 331/DEL/2023[2008-09]Status: DisposedITAT Delhi18 Jun 2024AY 2008-09

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Ms. Vandana Bhandari, CAFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 143(1)Section 154Section 244ASection 254

244A 3. Without prejudice, if jurisdiction of AO to re-determine interest u/s 244A requires examination of facts and not covered under "mistake apparent from record" u/s 154 then assessing officer should be directed to quash the order u/s 154 as it is void ab initio and assume re-determination ... through CPGRAM is hereby rejected. The CIT(A) has sustained the order of AO on the basis that 7. as there was no mistake apparent on record, petition under 154 of the Act was not maintainable. 8. We are of considered view that CIT(A) has fallen in error

Everest Business Advisory India Pvt Ltd, Gurgaon vs. ACIT Circle 7(1), New Delhi

ITA 330/DEL/2023[2007-08]Status: DisposedITAT Delhi18 Jun 2024AY 2007-08

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Ms. Vandana Bhandari, CAFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 143(1)Section 154Section 244ASection 254

244A 3. Without prejudice, if jurisdiction of AO to re-determine interest u/s 244A requires examination of facts and not covered under "mistake apparent from record" u/s 154 then assessing officer should be directed to quash the order u/s 154 as it is void ab initio and assume re-determination ... through CPGRAM is hereby rejected. The CIT(A) has sustained the order of AO on the basis that 7. as there was no mistake apparent on record, petition under 154 of the Act was not maintainable. 8. We are of considered view that CIT(A) has fallen in error

M/S. Philips India Limited (Successor to Erstwhile Philips Software Centre Pvt. Ltd.), Kolkata vs. D.C.I.T./A.C.I.T.(Transfer Pricing) - 2, Kolkata

In the result, appeal of the assessee in ITA No

ITA 33/KOL/2023[2004-2005]Status: DisposedITAT Kolkata11 Jun 2024AY 2004-2005

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Blei.T.A. No. 32 & 33/Kol/2023 Assessment Year: 2004-05 M/S. Philips India Limited Joint Commissioner Of Income-Tax 3Rd Floor, Tower A Vs (Transfer Pricing-Ii), Bangalore [Presently Deputy Dlf Park, 08 Block Af Commissioner/Assistant Major Arterial Road Commissioner Of Income-Tax New Town Transfer Pricing 2, Kolkata Kolkata - 700156 [Pan : Aabcp9487A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan K. Ved, A.R. Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 13/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/06/2024 आदेश/O R D E R Per Sanjay Garg: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”), Even Dt. 15/11/2022, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2004-05. 2. The Sole Issue Raised In Both The Appeals Is Relating To The Maintainability Of The Appeals Before The Ld. Cit(A) Against The Rectification Orders Passed By The Transfer Pricing Officer (In Short “Tpo”) U/S 154 R.W. Sub-Section (5) To Section 92Ca Of The Act. The Ld. Cit(A) Vide Impugned Orders Has Dismissed The Appeals Of The Assessee Holding That As Per The Provisions Of Section 246A Of The Act, Order U/S 92Ca Or Its Rectification Order U/S 154 Of The Act Passed By The Tpo Is 2

For Appellant: Shri Ketan K. Ved, A.RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 154Section 246ASection 250Section 92C

would reveal that a TPO may amend the order passed u/s 92CA(3) of the Act for the purpose of rectification of any mistake apparent from record in such order and the provisions of Section 154 will accordingly apply. Sub- Section (5), therefore, specifically provides that the provisions of Section ... Income-tax Authority as referred to in Section 116 may amend any order passed by it with a view to rectifying any mistake apparent on record in such order. By virtue of sub-Section (5) to Section 92CA, the aforesaid powers of rectification under Section 154 of the Act have

M/S. Philips India Limited (Successor to Erstwhile Philips Software Centre Pvt. Ltd.), Kolkata vs. D.C.I.T./A.C.I.T. (Transfer Pricing) - 2, Kolkata

In the result, appeal of the assessee in ITA No

ITA 32/KOL/2023[2004-2005]Status: DisposedITAT Kolkata11 Jun 2024AY 2004-2005

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Blei.T.A. No. 32 & 33/Kol/2023 Assessment Year: 2004-05 M/S. Philips India Limited Joint Commissioner Of Income-Tax 3Rd Floor, Tower A Vs (Transfer Pricing-Ii), Bangalore [Presently Deputy Dlf Park, 08 Block Af Commissioner/Assistant Major Arterial Road Commissioner Of Income-Tax New Town Transfer Pricing 2, Kolkata Kolkata - 700156 [Pan : Aabcp9487A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan K. Ved, A.R. Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 13/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/06/2024 आदेश/O R D E R Per Sanjay Garg: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”), Even Dt. 15/11/2022, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2004-05. 2. The Sole Issue Raised In Both The Appeals Is Relating To The Maintainability Of The Appeals Before The Ld. Cit(A) Against The Rectification Orders Passed By The Transfer Pricing Officer (In Short “Tpo”) U/S 154 R.W. Sub-Section (5) To Section 92Ca Of The Act. The Ld. Cit(A) Vide Impugned Orders Has Dismissed The Appeals Of The Assessee Holding That As Per The Provisions Of Section 246A Of The Act, Order U/S 92Ca Or Its Rectification Order U/S 154 Of The Act Passed By The Tpo Is 2

For Appellant: Shri Ketan K. Ved, A.RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 154Section 246ASection 250Section 92C

would reveal that a TPO may amend the order passed u/s 92CA(3) of the Act for the purpose of rectification of any mistake apparent from record in such order and the provisions of Section 154 will accordingly apply. Sub- Section (5), therefore, specifically provides that the provisions of Section ... Income-tax Authority as referred to in Section 116 may amend any order passed by it with a view to rectifying any mistake apparent on record in such order. By virtue of sub-Section (5) to Section 92CA, the aforesaid powers of rectification under Section 154 of the Act have

Inmobi Technology Services Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle3(1)(1), Bangalore

In the result appeals filed by assessee for AY

ITA 303/BANG/2022[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A Nos. 303 & 839/Bang/2022

For Appellant: Shri Chaitanya, Sr. Advocate a/wFor Respondent: Ms. Neera Malhotra, CIT-DR
Section 143(2)Section 143(3)Section 92C

authority referred to in section 116 of the Act. If one is to proceed on the basis that suo moto rectification of mistake apparent on record is also to be Page 44 of 86 IT(TP)A Nos. 303 & 839/Bang/2022 carried out within the time limit prescribed under section

M/S Sms Infrastructure Ltd, Nagpur vs. D.C.I.T. Centralcircle 2(3), Nagpur

In the result, assessee’s appeal is dismissed

ITA 566/NAG/2016[2008-09]Status: DisposedITAT Nagpur03 Jun 2024AY 2008-09

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Saket BhattadFor Respondent: Shri Abhay Marathe
Section 131Section 132Section 139(1)Section 143(3)Section 154Section 801ASection 80ASection 80I

assessee, he cannot disallow the same under section 154 of the Act. Originally the order passed by the Assessing Officer is not a mistake apparent on record and it cannot be rectified under section 154 of the Act. He further submitted that whether the Assessing Officer can invoke the provisions ... facie, the Assessing Officer committed a patent mistake allowing the claim of the assessee. The mistake committed by the Assessing Officer is a mistake apparent on record. In our opinion, the mistake committed by the Assessing Officer which is apparent on record can be rectified by the Assessing Officer under

Suchi Agrawal, Noida vs. ITO Ward 5(2)(4), Noida

ITA 601/DEL/2024[2020-21]Status: DisposedITAT Delhi31 May 2024AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Akash Vajpai, Adv. and Ms. Shweta ShandiyalFor Respondent: Shri Om Prakash, Sr. Dr
Section 143(1)Section 154Section 90

view not allowing foreign tax credit by AO (CPC) was nothing, but a mistake apparent on record. Therefore, we direct the revenue to allow the claim of the assessee. In the case of Vikash Daga vs. ACIT (supra), held as under:- “8. We have given a thoughtful consideration

Samsung C and T Corporation India Pvt. Ltd., Gurgaon vs. DCIT Circle 22(2) Delhi, New Delhi

In the result, appeal is allowed

ITA 2184/DEL/2023[2018-19]Status: DisposedITAT Delhi30 May 2024AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Shri Brajesh Kumar Singhassessment Year: 2018-19

Section 115JSection 143(1)Section 143(1)(a)Section 154

column specified for capital and personal expenditure, the CPC has correctly made the adjustment and it is not a case of mistake apparent on record so as to rectify under section 154 of the Act. 8. We have considered rival submissions and perused the materials on record. Perusal

Elaiyur Hwcs Ltd., Perambalur vs. ITO, Ward -1, Perambalur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 341/CHNY/2024[2009-10]Status: DisposedITAT Chennai29 May 2024AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.341/Chny/2024 िनधा"रण वष"/Assessment Year: 2009-10 Elaiyur Hwcs Ltd., Vs. The Income Tax Officer, 2/23, Elaiyur Po, Vailyankaval Via, Ward 1, Perambalur, Tamil Nadu 621 806. Perambalur. [Pan: Aaaae1370Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri P.M. Kathir, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.05.2024 घोषणा की तारीख /Date Of Pronouncement : 29.05.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal By The Assessee Is Against The Order Dated 18.12.2023 Passed By The Ld. Cit(A) [Nfac] For The Assessment Year 2009-10. 2. The Assessee Raised Five Grounds Of Appeal Amongst Which The Only Issue Emanates For Our Consideration Is To Whether The Ld. Cit(A) Was Justified In Confirming The Order Of The Assessing Officer In Denying The Rectification Petition Filed By The Assessee Under Section 154 Of The Act To Rectify The Mistake Apparent On Record.

For Appellant: Shri P.M. Kathir, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 143(1)Section 154

order of the Assessing Officer in denying the rectification petition filed by the assessee under section 154 of the Act to rectify the mistake apparent on record. 2 I.T.A. No.341/Chny/24 3. The assessee is a weaver’s co-operative society registered under the Tamilnadu Co-operative Societies Registration

The Vejalpur Nagrik Sahakari Bank Ltd., Panchmahal vs. The Asstt.CIT., Anand Circle, Anand

ITA 1031/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad15 May 2024AY 2017-18

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

For Appellant: Shri Sakar Sharma, A.RFor Respondent: Shri H. Phani Raju, CIT-D.R
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 154Section 269Section 269SSection 292BSection 51Section 69A

made u/s 26955 in order passed u/s 143(3) dtd 29-12-2019 with section 69A without appreciating that neither such substation an mistake apparent on record not is permissible within the meaning of section 292B of the Act in as much as conditions specified in section 69A are also

The Vejalpur Nagrik Sahakari Bank Limited, Panchmahal vs. The Asstt. CIT., Anand Circle, Anand

ITA 1030/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad15 May 2024AY 2017-18

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

For Appellant: Shri Sakar Sharma, A.RFor Respondent: Shri H. Phani Raju, CIT-D.R
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 154Section 269Section 269SSection 292BSection 51Section 69A

made u/s 26955 in order passed u/s 143(3) dtd 29-12-2019 with section 69A without appreciating that neither such substation an mistake apparent on record not is permissible within the meaning of section 292B of the Act in as much as conditions specified in section 69A are also

Sondekoppa Sundarswamy Naganand, Bangalore vs. Assistant Commissioner of Income Tax, Circle-2(2)(1), Bangalore

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

ITA 607/BANG/2024[2017-18]Status: DisposedITAT Bangalore13 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri V. Parithivel, D.R

computation sheet which is forming part of the assessment order is wrong and he ought to have that noticed that it is a mistake apparent on record & is a subject matter of rectification. He ought to have noticed that the AO had committed an error while preparing the computation sheet

Renault Nissan Technology & Business Centre India Private Limited, Kanchipuram vs. ACIT, Corporate Circle 5(1), Chennai

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 914/CHNY/2023[2011-12]Status: DisposedITAT Chennai30 Apr 2024AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.913 & 914/Chny/2023 िनधा"रण वष"/Assessment Years: 2010-11 & 2011-12 Renault Nissan Technology & Vs. The Assistant Commissioner Of Business Centre India Private Limited, Income Tax, Corporate Circle 5(1), Tp2/1, Ascendas It Park, Natham Main Building, Aayakar Bhavan, Sub Post Office, Mahindra World City, No. 121, M.G. Road, Kanchipuram District, Nungambakkam, Chennai 600 034. Tamil Nadu 603 004. [Pan:Aadcr7253E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 24.04.2024 घोषणा की तारीख /Date Of Pronouncement : 30.04.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Against Separate Orders Both Dated 23.06.2023 Passed By The Nfac [Cit(A)] For The Assessment Year 2010-11 & 2011-12 Respectively.

For Appellant: Shri Ashik Shah, C.AFor Respondent: Shri Nilay Baran Som, CIT
Section 10A

rectification application on 12.02.2019, which is at page 177 of the paper book and vide para No. 2, sought for to rectify the mistake apparent on record in not excluding other income to the extent of ₹.41,03,158/-. Therefore, the Assessing Officer is directed to pass order in rectification

Renault Nissan Technology& Business Centre India Private Limited, Kanchipuram vs. ACIT, Corporate Circle 5(1), Chennai

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 913/CHNY/2023[2010-11]Status: DisposedITAT Chennai30 Apr 2024AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.913 & 914/Chny/2023 िनधा"रण वष"/Assessment Years: 2010-11 & 2011-12 Renault Nissan Technology & Vs. The Assistant Commissioner Of Business Centre India Private Limited, Income Tax, Corporate Circle 5(1), Tp2/1, Ascendas It Park, Natham Main Building, Aayakar Bhavan, Sub Post Office, Mahindra World City, No. 121, M.G. Road, Kanchipuram District, Nungambakkam, Chennai 600 034. Tamil Nadu 603 004. [Pan:Aadcr7253E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 24.04.2024 घोषणा की तारीख /Date Of Pronouncement : 30.04.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Against Separate Orders Both Dated 23.06.2023 Passed By The Nfac [Cit(A)] For The Assessment Year 2010-11 & 2011-12 Respectively.

For Appellant: Shri Ashik Shah, C.AFor Respondent: Shri Nilay Baran Som, CIT
Section 10A

rectification application on 12.02.2019, which is at page 177 of the paper book and vide para No. 2, sought for to rectify the mistake apparent on record in not excluding other income to the extent of ₹.41,03,158/-. Therefore, the Assessing Officer is directed to pass order in rectification

Sandeep Singhal, Bengaluru vs. Assistant Commissioner of Income-Tax, Circle-4(1)(1), Bangalore

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

ITA 820/BANG/2023[2018-19]Status: DisposedITAT Bangalore30 Apr 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Subramanian S. Jt.CIT(DR)(ITAT), Bengaluru
Section 10Section 143(1)Section 143(3)Section 154Section 156Section 234C

interest u/s. 234C should also be reduced. He submitted the assessee has computed the interest of Rs.9,84,375. Therefore there is a mistake apparent on record on the interest u/s. 234C, to which the CIT(Appeals) has without deciding the issue on merits, dismissed the appeal of the assessee