“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

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

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

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

Raja Reddy Nalla, Warangal vs. DCIT., Central Circle-1(3), Hyderabad

In the result, the appeals filed by the assessee are dismissed for both the assessment years

ITA 550/HYD/2025[2014-15]Status: DisposedITAT Hyderabad24 Dec 2025AY 2014-15

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.549 & 550/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2013-14 & 2014-15) Shri Raja Reddy Nalla, Dy. Commissioner Of Income Tax, Vs. Central Circle 1(3), Hyderabad. Warangal. Pan : Aaxpn3602Q (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Poorna Chander Rao, C.A. रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 22/12/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025

For Appellant: Shri Poorna Chander Rao, C.AFor Respondent: Dr. Sachin Kumar, SR-DR

Section 115BSection 132Section 153ASection 154Section 69

section 115BBE of the Act without appreciating the fact that it is a case of change of opinion but not a case of mistake apparent on record which can be considered u/s. 154 of the Act. The learned counsel for the assessee further submitted that, the assessee has explained ... without there being any change in fact amounts to change of opinion but not a case of prima facie mistake apparent on record from the assessment order which can be rectified u/s. 154 of the Act. The assessee further contended that he had explained the transactions recorded in the seized

Raja Reddy Nalla, Warangal vs. DCIT., Central Circle-1(3), Hyderabad

In the result, the appeals filed by the assessee are dismissed for both the assessment years

ITA 549/HYD/2025[2013-14]Status: DisposedITAT Hyderabad24 Dec 2025AY 2013-14

For Appellant: Shri Poorna Chander Rao, C.AFor Respondent: Dr. Sachin Kumar, SR-DR

Section 115BSection 132Section 153ASection 154Section 69

Piyush Garg, Ahmedabad vs. DCIT, CC-1(2), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1590/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2022-23

For Appellant: Shri Anurag Sinha, A.RFor Respondent: Shri Uday Kishanrao Kakne, Sr. D.R

Section 115BSection 132ASection 143(1)Section 143(3)Section 154Section 271A

present case Section 271AAB was wrongly mentioned instead of Section 271AAC. This can be rectified as there was mistake apparent on record and there was no debate in imposing penalty u/s. 271AAC in present assessee’s case. Thus, the Assessing Officer rightly rectified the same. The contention ... order and that too after assessee’s submission in response of Section 271AAB proceedings cannot sustain as the Assessing Officer when realised the mistake apparent from record has to rectify the same u/s. 154 of the Act which the Assessing Officer has done in present case. Thus, the case laws

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

ought to have deleted the additions/disallowances made in intimation u/s.143(1) and Rectification order u/s.154, since such adjustments does not comprise of the mistake apparent on record. (vi)The Ld. CIT(A) erred in confirming the total income as processed by the CPC, on ignoring the fact that the notice ... processed under section 143(1) by CPC(Central Processing Unit) u/s.143(1) of the Act vide order dated 31.03.2021), hence, it is a mistake apparent from record, which needs correction. Therefore, Ld. Counsel for the assessee submitted that the order passed by the CPC u/s.143(1) of the Act, dated

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 498/RJT/2025[2015-16]Status: DisposedITAT Rajkot08 Dec 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos. 498 & 499/Rjt/2025 निर्धारणवर्ष /Assessment Years: 2015-16 & 2020-21 Gopal Snacks Pvt. Ltd. बनाम Asst. Commissioner Of Income Tax Circle-1(1), Rajkot Plot No.2322-2324, Gidc Metoda, Lodhika, Rajkot, Gujarat-360021 (अपीलार्थी/Appellant) Pan : Aadcg6113A (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राजस्व की ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख/Date Of Pronouncement : 08/12/2025 Order Per, Dr. Arjun Lal Saini: Captioned Two Appeals Filed By The Same Assessee, Pertaining To

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

SV vs. N Chikkala Sesharao, Kakinadavs.Income Tax Officer, Ward-3, Kakinada

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

ITA 564/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble

Section 143(1)Section 154Section 96

before the Centralized Processing Centre, Bangalore (in short “CPC”) on 18.04.2017. The CPC, Bangalore, observed that there is no mistake apparent on record and hence rejected the petition filed under section 154 of the Act. 3. On being aggrieved by the order of the CPC, Bangalore, the assessee filed ... filing a rectification petition under section 154 of the Act. The CPC, Bangalore has rightly rejected the rectification petition as there is no mistake apparent on record in the Return of income filed by the assessee, which can be rectified under section 154 of the Act. However

Andhra Pradesh State Civil Supplies Corporation Limited, Kanuru vs. ITO, TDS, Ward(1), Eluru

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

ITA 29/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam03 Dec 2025AY 2019-20

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.29/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2019-20) Vs. Andhra Pradesh State Civil The Income Tax Officer (Tds)-Ward-1 Eluru – 534001 Supplies Corporation Limited Andhra Pradesh 10-152/1, 4Th Floor Sai Towers, Ashok Nagar Bandar Road, Kanuru – 520007 Andhra Pradesh [Pan: Aabca7161R]

Section 154Section 201(1)Section 249(2)Section 249(3)

working out the TDS totaling to Rs. 2,36,43,317/-. Subsequently, the Ld. AO observed that a mistake apparent on record in the calculation of non-deduction of TDS for Paddy Procuring Commission and later passed a rectification order U/s. 154 of the Act dated 02/12/2019 by enhancing ... received. In the meantime, the Ld.AO passed one more order under section 154 of the Act for rectifying the mistake apparent from record vide order dated 02.12.2019 which was served on the assessee on 03.12.2019. Ld.AR further submitted that appeal against the order under section 154 of the Act dated

Microsoft Corporation (India) Private Limited, New Delhi vs. Principal Commissioner of Income Tax, Delhi

In the result, appeal filed by the assessee is allowed

ITA 2933/DEL/2025[2019-20]Status: DisposedITAT Delhi26 Nov 2025AY 2019-20

Section 143(1)Section 143(3)Section 154Section 263

that in terms of aforesaid rectification order passed u/s 154/143(3) of the Act where the AO admitted the protective addition made being mistake apparent on record and thus rectified. It is further seen that the addition of Rs.54,15,901/- made in the order by the CPC and further

Ahmedabad Maliya Tollway Ltd., Chennai vs. ITO, Corporate Ward-1(1), Chennai

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

ITA 538/CHNY/2025[2018-19]Status: DisposedITAT Chennai20 Nov 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. N.V. Balaji, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T

Section 115Section 115JSection 143(1)Section 143(3)Section 154Section 37

profit u/s.115JB of the Act. The assessee resisted the rectification by arguing that the proposed rectification is not in the nature of a ‘mistake apparent on record’ as envisaged u/s.154 of the Act, rather, it is a technical addition. Thereafter, the rectification order came to be passed u/s.154 ... further argued that the rectification ought not to be done, when the issue sought to be rectified is debatable in nature. Only mistakes apparent on record could be rectified u/s.154 of the Act and that in the instant case, the rectification that was done did not qualify to be termed

Standard Castings Pvt Ltd, Delhi vs. ITO Ward-24(1), Delhi

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

ITA 4406/DEL/2025[2018-19]Status: DisposedITAT Delhi19 Nov 2025AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: Shri Satyen Sethi, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 115JSection 143Section 143(1)Section 143(3)Section 154

case is selected for scrutiny the order passed u/s 143(1) is merged with the regular assessment and if there is any mistake apparent on record in the return of income, it is open for the JAO to process the same and make the adjustment. In the given case ... uncalled for and negligence on the part of Assessing Officer. Therefore, we are inclined to direct the Assessing Officer to rectify the mistake apparent on record and delete the demand raised in order passed u/s 143(1) of the Act. 11. In the result, the appeal filed by the assessee

DCIT, Chennai vs. Jagathrakshakan Srinisha, Chennai

ITA 1271/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T

Section 131Section 132Section 143(3)Section 154Section 270A

even though addition was made as 'unexplained investment', yet, the provisions of section 115BBE of the Act was not invoked, which constitutes a mistake apparent on record. Accordingly, in terms of section 115BBE of the Act, the tax was recomputed at 60% and surcharge was levied ... adopted :-20-: ITA. Nos.: 1253, 1264 & 1271 /Chny/2025 in the Assessment Order passed u/s 143(3) of the Act, construing it as a 'mistake apparent from record' to be rectified u/s 154 of the Act. 3. In this regard, it is submitted that the increase in tax rates

DCIT, Chennai vs. Jagathrakshakan Srinisha, Chennai

ITA 1264/CHNY/2025[2017]Status: DisposedITAT Chennai18 Nov 2025

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T

Section 131Section 132Section 143(3)Section 154Section 270A

even though addition was made as 'unexplained investment', yet, the provisions of section 115BBE of the Act was not invoked, which constitutes a mistake apparent on record. Accordingly, in terms of section 115BBE of the Act, the tax was recomputed at 60% and surcharge was levied ... adopted :-19-: ITA. Nos.: 1253, 1264 & 1271 /Chny/2025 in the Assessment Order passed u/s 143(3) of the Act, construing it as a 'mistake apparent from record' to be rectified u/s 154 of the Act. 3. In this regard, it is submitted that the increase in tax rates

DCIT, Chennai vs. Jagathrakskan Srinisha, Chennai

In the result, the appeals filed by the Revenue in I

ITA 1253/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T

Section 131Section 132Section 143(3)Section 154Section 270A

even though addition was made as 'unexplained investment', yet, the provisions of section 115BBE of the Act was not invoked, which constitutes a mistake apparent on record. Accordingly, in terms of section 115BBE of the Act, the tax was recomputed at 60% and surcharge was levied ... adopted :-20-: ITA. Nos.: 1253, 1264 & 1271 /Cltity/2025 in the Assessment Order passed u/s 143(3) of the Act, construing it as a 'mistake apparent from record' to be rectified u/s 154 of the Act. 3. In this regard, it is submitted that the increase in tax rates

Ziqitza Healthcare Ltd, Mumbai vs. Pr. Commissioner of Income Tax -4, Mumbai

In the result, the appeal is accordingly, allowed

ITA 3637/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Nov 2025AY 2020-21

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri Prabhash Shankar, Hon’Bleziqitza Healthcare Ltd., Principal Cit - 4, 23, Sunshine Tower, Mumbai. Vs. Senapati Bapat Marg, Delisle Road, Dadar West, Mumbai 400 013. Pan Aaacz1733C (Appellant) (Respondent)

For Appellant: Shri Ketan L Vajani-CAFor Respondent: Shri Arun Kanti Datta – CIT-DR

Section 143(3)Section 263Section 36(1)(va)

context of rectification provisions u/s. 254(2) of the Act that the subsequent change of law cannot make the order erroneous as displaying mistake apparent on record. It is not necessary to multiply authorities on the point particularly in view of the decision of Supreme Court in the case

District Co-Opertive Sugar Cane Supply Ltd., Bareilly vs. ITO Range-1(1), Bareilly

In the result, in the combined result in ITA

ITA 578/LKW/2024[2018-19]Status: DisposedITAT Lucknow30 Oct 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(3)Section 154Section 80P

i.r.o completed Assessment by resorting to proceedings u/s 154 of IT Act without considering that it is not a case of ‘mistake apparent from record and thus initiation of rectification proceedings is invalid, illegal ab initio and liable to be quashed. 2. That the Authorities below erred on facts ... Rs.52,66,764/- was categorized in the balance-sheet as under the head other receivable from the sugar mills. Therefore, treating it as mistake apparent on record, the Assessing Officer re-computed the income of the assessee and ITA. Nos. 577 & 578/LKW/2024 Page 4 of 21 made impugned addition

District Co-Opertive Sugar Cane Supply Ltd, Bareilly vs. ITO Range-1(2), Bareilly

ITA 577/LKW/2024[2016-17]Status: DisposedITAT Lucknow30 Oct 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(3)Section 154Section 80P

Baani Landbase Private Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, appeal of the Assessee is allowed

ITA 5944/DEL/2024[2015-16]Status: DisposedITAT Delhi30 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.5944/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Baani Landbase Pvt Ltd., Dcit, Corporate One, Ground Floor, Vs. Circle-4(2), Plot No.5, District Center, Jasola, Central Revenue Building, Delhi. I.P. Estate, Delhi. Pan No.Aadcb0237E अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 154Section 156Section 292B

face of the order; (iii) That the proceedings u/s 154 of the Act initiated vide Notice dated 26.04.2021 do not constitute mistake apparent from record, for the reason that the same issue was examined during assessment proceedings and constitutes change of opinion; (iv) That the addition made ... pursuant to mistake apparent from record particularly as Ld. AO had issued Notice u/s 148 of the Act dated 30.06.2021 for the reassessment. 3. That without prejudice to the aforesaid grounds of Appeal it is contended on merits, that the Ld. AO while making the impugned addition

Forum Agro Foods Pvt. Ltd., New Delhi vs. ACIT, Central Circle-19, New Delhi

ITA 483/DEL/2019[2014-15]Status: DisposedITAT Delhi29 Oct 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year : 2014-15 M/S Forum Agro Foods Pvt. Ltd., Vs. Acit, C-134, Defence Colony, Central Circle-19, New Delhi – 110 024. New Delhi. Pan: Aaacf8920D Assessee By : Ms Vanshika Mehta, Advocate & Shri Nirbhay Mehta, Advocate Revenue By : Ms Monika Singh, Cit-Dr Date Of Hearing : 28.08.2025 Date Of Pronouncement : 29.10.2025

For Appellant: Ms Vanshika Mehta, Advocate &For Respondent: Ms Monika Singh, CIT-DR

Section 143(3)Section 153ASection 153CSection 254(2)

appeal folder. Since, these additional grounds were not adjudicated at all by the Tribunal while disposing off the appeal which amounts a mistake apparent on record warranting rectification of the order u/s 254(2) of the Act. 4. Hence, we deem it fit and appropriate to recall the order passed

M/S. 9Th Street Architects, Ahmedabad vs. The Dy.CIT, Circle-4(1)(1), Ahmedabad

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

ITA 1463/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Divatia & Shri Samir Vora, ARsFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 133ASection 154Section 250Section 69A

income disclosed during survey. 2.1 The Ld.CIT(A) has grievously erred in law and on facts in confirming that there was a mistake apparent on record of not charging the income disclosed during the course of survey at a special rate u/s 115BBE so that the same could be rectified ... that the issue of charging tax at special rate u/s 115BBE being debatable and possible to have two views, it was not a mistake apparent from record which could be rectified u/s 154. 2.3 That in the facts and circumstances of the case as well as in law, the Ld.CIT

Venkatesh Raghav Rao Hebbani, New Delhi vs. Income Tax Officer Ward 34(5), New Delhi

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

ITA 474/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Shubham Jain, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 139(1)Section 147Section 148Section 148ASection 194ISection 271(1)(C)Section 271(1)(c)

assessee in response to the notice issued u/s 148 of the Act and the same return was accepted without there being any mistake apparent on record. It is also fact that assessee is a salaried employee and could not file return of income due to personal reasons. However, the majority