“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

Lintas Employees Health Assistance Trust, Mumbai vs. Income Tax Officer Ward 25(2)(1), Mumbai

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

ITA 4364/MUM/2025[2019-20]Status: DisposedITAT Mumbai25 Sept 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2019-20 Lintas Employees Health Income-Tax Officer, Assistance Trust Ward – 25(2)(1), 13Th Floor, Express Towers Mumbai Nariman Point, Vs. Mumbai – 400021 (Pan: Aaatl0325M) (Appellant) (Respondent) Present For: Assessee : Shri Prakash Jotwani & Ms Priya Gada, Advocates Revenue : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Girish Agrawal: This Appeal Filed By Assessee Is Against The Order Of Addl/Jcit (A)-1, Hyderabad Vide Order No. Itba/Apl/S/250/2024- 25/1074797264(1), Dated 21.03.2025 Passed Against The Intimation Issued By The Central Processing Centre Of The Department, Bengaluru (Cpc) U/S. 143(1) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 12.05.2020 For Assessment Year 2019-20. 2. Grounds Taken By The Assessee Are Reproduced As Under: Ground No. 1: Erred In Not Condoning Delay In Filing The Appeal The Ld. Cit(A) Erred In Dismissing The Appeal Without Considering The Merits Of The Case & Erred In Not Condoning The Delay Of 964 Days In Filing The Appeal

For Appellant: Shri Prakash Jotwani and Ms Priya Gada, AdvocatesFor Respondent: Shri Surendra Mohan, Sr. DR

Section 10(15)Section 10(35)Section 143(1)

Intimation Order u/s143(1), and that the same should have been a matter of scrutiny proceedings and therefore clearly it is a mistake apparent on record. GROUND NO. 3: DIVIDEND INCOME of Rs. 16,36,856/- The ld. CIT(A) failed to take into consideration that the Dividend income from ... from home during the covid LockDown), filed an online response to the outstanding demand, on the Income Tax Portal and intimated about the mistake apparent on record of the Intimation u/s 143(1), However, till date no response has been received from the Income Tax Department on this issue

Nidhika Rehani, New Delhi vs. ACIT, Circle 5(2)(2), Noida

In the result, appeal of the assessee is partly allowed

ITA 2236/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2017-18] Mrs. Nidhika Rehani, Vs Acit, G-7, Sector-6, Gautam Budh Circle-5(2)(2), Nagar, Noida, U.P.-201301. G.B.Nagar, Noida Pan-Arjpg8733C Appellant Respondent Appellant By Ms. Rano Jain, Adv., Ms. Mansi Jain, Ca & Ms. Shakshi Rustagi, Adv. Respondent By Shri Dheeraj Kumar Jain, Sr.Dr Date Of Hearing 23.06.2025 Date Of Pronouncement 17.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 27.06.2023 Passed By Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(Appeal) Ghaziabad/10645/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 21.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is An Individual & E- Filed Her Return Of Income On 31.10.2017, Declaring Total Income Of Inr 32,08,530/-.The Assessee Is Engaged In The Manufacturing & Trading Of Readymade Garments & Is Sole Proprietor Of M/S. Dsyngreen. Based On The Information Available On Record That Assessee Has Made Cash Deposits In The Bank Accounts During Demonetization In Specified Bank Notes (Sbn), Case Of The Assessee Was Taken Up For Scrutiny. After Considering The Submissions Made, Assessment Was Completed U/S 143(3) At A Total Income Of Inr 2,03,49,108/- By Making Following Additions/Disallowances:-

Section 143(3)Section 250Section 68Section 69Section 69C

giving any reasons. The appellant contends that on the facts and in the circumstances of the case and in law, this being a mistake apparent on record, a suitable direction may be given to the Assessing Officer. The appellant craves leave to add to, alter or amend the aforestated grounds

Eagle Fashions Private Limited, Surat vs. DCIT Circle 1(1)(1), Surat

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1252/SRT/2024[2011-12]Status: DisposedITAT Surat12 Sept 2025AY 2011-12

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.1252/Srt/2024 िनधा"रण वष" /Assessment Year : 2011-12 Eagle Fashions Private The Deputy Director Of Income Limited, 201, 2Nd Floor बनाम/ Tax, Cpc, Bengaluru Orleaans Building Current Jurisdiction: V/S. Near City Centre Deputy Cit Sosyo Circle, Magdalla Circle-1(1)(1), Surat Bharthana B.O., Surat "थायी लेखा सं./Pan: Aaace 5107 F (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/06/2025 घोषणा की तारीख /Date Of Pronouncement: 12/09/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Office Of The Commissioner Of Income Tax, Appeal, Addl/Jcit (A), Prayagraj [Hereinafter Referred To As ‘Ld.Cit(A)’] Dated 30/09/2024 For Assessment Year (Ay) 2011-12. The Assessee Is Aggrieved By The Action Of The Ld.Cit(A) In Dismissing The Appeal Of The Assessee Holding The Same As Time- Barred. Eagle Fashions Private Limited Vs. Dcit Asst. Year : 2011-12

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 143(1)Section 154Section 250

noting down the figures of opening balance of the written down value of land and furniture. As it was a case of mistake apparent on record, assessee filed multiple rectification applications u/s. 154 of the Act on different dates le. 15.01.2019, 25.01.2019, 24.01.2020 and 05.02.2020. 3. The assessee pleaded ... reason that the assessee was pursuing its alternative remedy by filing application u/s.154 of the Act for rectification of mistake apparent on record. He has further submitted Eagle Fashions Private Limited vs. DCIT Asst. Year : 2011-12 4 that the assessee has a fair case on merits as there

Haripriya Tekupally, Hyderabad vs. Income Tax Officer, Int Txn - 2, Hyderabad

In the result appeal ITA

ITA 787/HYD/2024[2014-15]Status: DisposedITAT Hyderabad10 Sept 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, P R SureshFor Respondent: Sri Siva Prasad, SV, Sr. AR

Section 142(1)Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 54F

ITA.Nos.786 & 787/Hyd./2024 qua grounds nos.6 and 7 of assessee’s appeals for re- adjudication on the ground that, there is a mistake apparent on record in not specifically adjudicating ground nos.6 and 7 of assessee’s appeals. Therefore, the present appeals ITA.Nos.786 & 787/Hyd./ 2024 were heard

Gangaram Reddy Tekulapalli, Hyderabad vs. ITO., Int Taxn- 2, Hyderabad

In the result appeal ITA

ITA 786/HYD/2024[2014-15]Status: DisposedITAT Hyderabad10 Sept 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, P R SureshFor Respondent: Sri Siva Prasad, SV, Sr. AR

Section 142(1)Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 54F

Sh. Nanu Ram Choyal, Jaipur vs. ITO, Ward-Behror, Alwar

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

ITA 1015/JPR/2025[2011-12]Status: DisposedITAT Jaipur28 Aug 2025AY 2011-12

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 154

filed by the assessee, by observing as under:- ‘’6. Decision: Under the provisions of section 154 of the Act, the term "mistake apparent from record refers to an error that is evident on the face of the record without the need for extensive investigation or examination of facts and evidence ... Accordingly, under the provisions of section 154 of the Act, following errors can be considered as 'mistake apparent from record a) An error of fact b) An arithmetic mistake c) A small clerical error d) An error due to overlooking compulsory provisions of law. During the rectification proceedings, the appellant

Kalpesh Dhanjibhai Makasana, Surendranagar vs. Pr. CIT, Ahmedabad-3, Ahmedabad

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

ITA 1231/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(2)Section 143(3)Section 14ASection 263Section 80GSection 80G(5)Section 80G(5)(vi)

order considering the case of “limited scrutiny” under regular assessment and allowed the appeal filed by the assessee. Since there is no mistake apparent on record from the order passed by the Tribunal, the Miscellaneous Application was also dismissed by the Tribunal. Thus dismissed the Revenue’s appeal by observing ... filed the rectification application as the Tribunal has already considered the same. 6. We are therefore of the opinion that there is no mistake apparent on record from the order passed by the Tribunal in the Appeal so as to entertain the Misc. Application under Section

Trimurti Co-Op Credit Society Limited, Mumbai vs. Income Tax Officer Ward 19(3)(1), Mumbai, Piramal Chamber

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

ITA 3648/MUM/2025[2019-20]Status: DisposedITAT Mumbai22 Aug 2025AY 2019-20

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.3648/Mum/2025 "नधा"रण वष" / Assessment Year :2019-20 Trimurti Co-Operative Credit Society Limited 2 Ground Floor, Suparshwa Darshan Chs V.P Road, Mumbai-400 004 Pan : Aabat8982E ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-19(3)(1), Mumbai ……""यथ" / Respondent

For Appellant: Shri Satya Prakash SinghFor Respondent: Shri Aditya Rai, Sr. DR

Section 143(1)Section 154Section 250Section 80P(2)(d)

present case, the assessee, as stated at bar by the Ld Counsel of the assessee, was in the process for rectification of mistake apparent on record u/s. 154 of the Act, to which no effect was given by the department till the filing of the appeal. If such averment

Central Bank of India, Mumbai vs. CIT(A)-3, Mumbai

In the result, the appeal by the Revenue for the

ITA 5346/MUM/2018[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR

Section 10Section 115JSection 14ASection 250Section 37(1)

order has not provided any evidence before us to counter the said workings given before the Id. CIT(A) is incorrect. This constitutes mistake apparent on record within the meaning of Section 264(2) of the Act. 5.2 We find that the aforesaid resale has been rightly pointed

Jt. CIT (OSD) -2(1)(2), Mumbai vs. Central Bank of India, Mumbai

In the result, the appeal by the assessee for the

ITA 3674/MUM/2018[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR

Section 10Section 115JSection 14ASection 250Section 37(1)

order has not provided any evidence before us to counter the said workings given before the Id. CIT(A) is incorrect. This constitutes mistake apparent on record within the meaning of Section 664(2) of the Act. 5. 2. We find that the aforesaid resale has been rightly pointed

DCIT 2(1)(1), Mumbai vs. Central Bank of India, Mumbai

In the result, the appeal by the assessee for the

ITA 1223/MUM/2018[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR

Section 10Section 115JSection 14ASection 250Section 37(1)

assessee has not provided any evidence before us to counter the said workings given before the Id. CIT(A) is incorrect. This constitutes mistake apparent on record within the meaning of Section 664(2) of the Act. 5.2 We find that the aforesaid resale has rightly been pointed

St Marys Education Society Aligarh, Aligarh vs. Deputy Commissioner of Income-Tax, Exemption Circle, Ghaziabad

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

ITA 580/DEL/2024[2014-15]Status: DisposedITAT Delhi22 Aug 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 10Section 12ASection 143(1)Section 154Section 250

appeal before Ld. CIT(A) who dismissed the appeal by holding that it is not a matter of rectification as there was no mistake apparent on record. It is further seen that Ld.CIT(A) has decided the appeal ex-parte as the assessee has failed to file any submissions

Saint Marys School, Mainpuri vs. ADIT, Exepmtion Circle, Ghaziabad

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

ITA 1667/DEL/2023[2019-20]Status: DisposedITAT Delhi22 Aug 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2014-15] St. Marys Education Vs Dcit (Exemption), Society, Our Lady Circle, Ghaziabad Fatima Secondary School, Ram Ghat Road, Aligarh, U.P-201002. Pan-Aaats4351G Appellant Respondent Appellant By None Respondent By Shri Mahesh Kumar, Cit Dr [Assessment Year : 2019-20] Saint Marys School, Vs Asst. Director Of Opp. Kotwali Mainpuri, Income Tax, Uttar Pradesh-205001. Exemption Circle, Pan-Aaets1727L Ghaziabad. Appellant Respondent Appellant By Shri Vikesh Bansal, Ca Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 03.06.2025 Date Of Pronouncement 22.08.2025 Order Per Manish Agarwal, Am : Both The Captioned Appeals Are Filed By The Assessee Against The Separate Orders Dated 15.12.2023 & 31.03.2023 Passed By Ld. Commissioner Of Income Tax, National Faceless Appeal Centre & 1667/Del/2023 (“Nfac”), Delhi [“Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Against The Intimation U/S 143(1) By Cpc Dated 25.11.2019 & 26.05.2020 For Assessment Years 2014-15 & 2019- 20 Respectively.

Section 10Section 12ASection 143(1)Section 154Section 250

Hi Techno Control System Pvt Ltd, Dombivili vs. Ds Commissioner of Income Tax (Appeal), Mumbai

ITA 1525/MUM/2022[2016-17]Status: DisposedITAT Mumbai21 Aug 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.1525/Mum/2022 निर्धारण वर्ष / Assessment Year :2016-17 Hi Techno Control System Pvt. Ltd. Plot No.1, Bali8Ram Patil Industrial Estate, Kalyan Shili Road, Behind G.R. Patil College, Sonarpada, Kalyan-Dombivali-421 204 Pan : Aacch0649D ........अपीलार्थी / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Appeals) Mumbai ......प्रत्यर्थी / Respondent Assessee By : None Revenue By : Shri Himanshu Joshi, Sr. Dr सुनवाई की तारीख / Date Of Hearing :20.08.2025 घोषणा की तारीख / Date Of Pronouncement : 21.08.2025 2 Hi Techno Control System Pvt. Ltd. Vs. Deputy Commissioner Of Income Tax (Appeals), Mumbai

For Appellant: NoneFor Respondent: Shri Himanshu Joshi, Sr. DR

Section 154Section 200ASection 234ESection 254(2)Section 272ASection 272A(2)(K)Section 272A(2)(k)

matter has been recalled, on the request of the revenue by filing of Miscellaneous Application, raising the ground that there is a mistake apparent on record within the meaning of section 254(2) of the act, that the impugned order u/s 272A(2)(K) dated 19/02/2020, challenged by the assessee

Shri Sain Samaj Co-Operative Thrift and Credit Society Limited, Delhi vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee in ITA No

ITA 1597/DEL/2025[2019-20]Status: DisposedITAT Delhi19 Aug 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Mohit Chaudhary, CAFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(1)Section 154Section 80PSection 80P(2)(a)

amounting to Rs. 69,12,760/-, which was rejected on the ground that there is no mistake apparent on record vide order dated 11.05.2021. 4. On appeal before the CIT(A), the CIT(A) declined to interfere with the intimation passed

The New Vikash Co-Op. House Building Society Ltd., Faridabad vs. ITO, Ward-2(1), Faridabad

In the result, appeal of the assessee is allowed

ITA 4507/DEL/2024[2010-11]Status: DisposedITAT Delhi13 Aug 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2010-11] The New Vikash Co. House Vs Ito, Building Society Ltd., Ward-2(1), Advocate-Vijay Kumar Gupta, Faridabad. Opp.Jain Mandir-Main Bazar, Ballabgarh, Faridabad-121004 Pan-Aaajt1595P Appellant Respondent Appellant By Shri Vijay Kumar Gupta, Adv. Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.07.2025 Date Of Pronouncement 13.08.2025 Order

Section 143(3)Section 154Section 250Section 56Section 56(2)(vii)Section 56(2)(viii)Section 57

Ld.CIT(A) against that rectification order however, Ld.CIT(A) has not accepted the same for the sole reason that it is not a mistake apparent on record. 4. Against this order, the assessee is in appeal before us by taking following grounds of appeal:- 1. “THAT in the present case ... followed these directions and assessed the same under the head “capital gains”. According to ld.AR, this is the mistake apparent from record and deserves to be rectified. However, lower authorities had wrongly hold the same as not a mistake apparent from record. Thus, Ld.AR requested to direct

Income Tax Office Ward 52(5), Delhi vs. Imperial Exports, Delhi

Appeal of the Revenue is dismissed

ITA 1490/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Aug 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 115Section 115BSection 143(3)Section 154Section 250Section 69C

these should have been made u/s 69C r.w.s 115BBE of the Act. As the AO has not invoked these sections which is a mistake apparent on record, therefore, on the basis of such audit objection, rectification order was passed u/s 154 on 23.08.2022 wherein the AO observed that the additions ... judgement of Co-ordinate Bench, Jaipur in the case of Sudesh Kumar Gupta (supra). This error Page | 4 ITA No.1490/Del/2024 is not the mistake apparent from record which could be rectified u/s 154 of the Act. Moreover, the assessment year under appeal is AY 2017-18 and Hon’ble Madras

Shri Kutch Visa Oswal Jain Derawasi Sangh Bidada, Mandvi vs. The ITO Exemption, Ward (1), Rajkot.

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

ITA 160/RJT/2025[2017-18]Status: DisposedITAT Rajkot04 Aug 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 160/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Shri Kutch Visa Oswal Jain Derawasi The Ito Exemption, Ward (1), Vs. Sangh Bidada, P.O. Bidada, Rajkot. New Aayakar Bhavan, Race Mandvi 370435 Course Ring Road, Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabts0457L (Appellant) (Respondent)

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 11Section 11(2)Section 143(1)Section 143(1)(a)Section 154

grievance of the assessee that typographical error which has happened while filing the e-return. Thus, this is the clear case of mistake apparent on record which is very well therefore, a rectifiable u/s. 153 of the Act, thus, both AO and Ld.CIT(A) has not properly appreciated the provision

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 1228/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 147

which has a limited scope as the jurisdiction u/s.154 of the Act can be exercised only in respect of any mistake apparent from record. Therefore the claim regarding the claim of ESOP expenditure in an appeal against the order passed u/s.154 of the Act, in our humble view ... maintainable. The jurisdiction u/s.154 of the Act is restricted to the plea relating to the mistake apparent on record and not relating to any other additional claim, which was either not allowed or not raised during the original assessment proceedings or any appellate proceedings relating to the original assessment proceedings

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 138/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2014-15

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 147