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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

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

Appeal is dismissed

ITA 855/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

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

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

Appeal is dismissed

ITA 1126/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

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

Lintas Employees Recreation Trust, Mumbai vs. ITO Ward 25(2)(1), Mumbai

Appeal is treated as allowed for statistical purposes

ITA 3747/MUM/2025[2021-22]Status: DisposedITAT Mumbai31 Jul 2025AY 2021-22

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Prakash JotwaniFor Respondent: Shri Surendra Mohan
Section 143(1)Section 154Section 250

Intimation Order u/s.143(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: LONG TERM CAPITAL LOSS OF INR.1,16,445/- The learned CIT(A) failed to take into consideration that the AO/CPC erred ... This caused immense delay in filing the appeal. (vi) The Assessee Trust contacted their lawyers who suggested that despite there merely being a mistake apparent on record which is clerical in nature, an appeal should be filed in order to get justice and equity. (vii) Accordingly, an appeal has been

Cci Chambers Co-Op Hsg Soc. Ltd, Mumbai vs. Income Tax Officer-17(2)(1), Mumbai

In the result, both the appeal

ITA 3543/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Prakash Jotwani

legal and valid, a 154, to the AO is legal and valid, as it is a mistake apparent on s it is a mistake apparent on record. (iii) The learned CIT(A) and AO/CPC erred in confirming the denial (iii) The learned CIT(A) and AO/CPC erred in confirming ... same in the Intimation u/s. 143(1) is a arbitrary denial of the same in the Intimation u/s. 143(1) is a mistake apparent on record, and therefore ought to be mistake mistake apparent on record, and therefore ought apparent on record, and therefore ought to be to be adjudicated

Cci Chambers Co-Op Hsg Soc. Ltd, Mumbai vs. ITO 17(2)(1), Mumbai

In the result, both the appeal

ITA 3542/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Prakash Jotwani

legal and valid, a 154, to the AO is legal and valid, as it is a mistake apparent on s it is a mistake apparent on record. (iii) The learned CIT(A) and AO/CPC erred in confirming the denial (iii) The learned CIT(A) and AO/CPC erred in confirming ... same in the Intimation u/s. 143(1) is a arbitrary denial of the same in the Intimation u/s. 143(1) is a mistake apparent on record, and therefore ought to be mistake mistake apparent on record, and therefore ought apparent on record, and therefore ought to be to be adjudicated

Gujarat State Petronet Limited, Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

In the result, appeal of the assessee stands allowed

ITA 991/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Guptaआयकर अपील सं /Ita No.991/Ahd/2025 िनधा"रण वष" /Assessment Year : 2012-13

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 115JSection 143(3)Section 154

surcharge and education cess can be allowed u/s.154 of the Act was a debatable issue and that it was not a case of mistake apparent from record, therefore, the AO did not have any jurisdiction to reduce the claim of the assessee by invoking the provisions of section ... credit u/s.115JAA of the Act is inclusive and surcharge and education cess. Under the circumstances, it was not a case of mistake apparent on record, rather it was a debatable issue and, therefore, the AO was not justified in reducing the MAT credit by invoking the provisions of section

Advance Lifespaces Private Limited, Ahmedabad vs. ACIT, Circle 1(1)(1), Ahmedabad

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

ITA 411/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad28 Jul 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2017-18 Advance Lifespaces Pvt. Ltd., Assistant Commissioner Of S-202/B/4/205, City Centre, Income Tax, Vs Nr. Idgah Gate, Asarwa, Circle-1(1)(1), Ahmedabad-380016 Ahmedabad [Pan No.:Aajca2338M] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Appellant By : Shri P. D. Shah, Ar & Shri Saiyam Shah, Ar Respondent By : Shri B.P. Srivastava, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 22.07.2025 घोषणा की तारीख /Date Of Pronouncement: 28.07.2025 आदेश/O R D E R Per T.R. Senthil Kumar: This Appeal Is Filed By The Assessee Against The Appellate Order Dated 03.07.2024 Passed By Ld. Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As “Ld. Cit(A)”), National Faceless Appeal Centre (In Short “Nfac”), Delhi Arising Out Of The Rectification Order Passed Under Section 154 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) Relating To The Assessment Year 2017-18. 2. The Registry Has Noted That There Is A Delay Of 145 Days In Filing The Present Appeal. The Assessee Explained Vide Notarized Affidavit Stated Originally The Appeal Was Filed By The Assessee By Paying Appropriate Fees On 30.08.2024 By E-Filing. However, There Is Some Mistakes In Form No. 36 Which Was Required To Be Rectified, The Same Was Rectified & Filed On 21.02.2025 Thereby The Registry Has Noted That There Is A Delay Of 145 Days. In View A.Y. 2017-18. 2 Of The Explanation Offered By The Assessee, The Delay Of 145 Days In Filing Of The Above Is Hereby Condoned.

For Appellant: Shri P. D. Shah, AR & Shri Saiyam Shah, ARFor Respondent: Shri B.P. Srivastava, Sr. DR
Section 143(3)Section 145(3)Section 154

doing so the claim of loss of Rs. 88,86,761/- which ought to have been disallowed but not disallowed, which is a mistake apparent on record. Therefore, Rectification Order was passed rectifying the total income to Rs. 2,88,52,653/-. 4. Aggrieved against the revision order, assessee filed

Shri Jivico Karmachari Co-Operative Credit Society Limited, Rajkot, Gujarat vs. Income Tax Officer, Ward 2(1)(1), Rajkot, Gujarat

In the result, appeal filed by the assessee is allowed

ITA 48/RJT/2025[2017-18]Status: DisposedITAT Rajkot21 Jul 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.48/Rjt/2025 ("नधा"रण वष" /Assessment Year: (2017-18) Shri Jivico Karmachari Co- Income Tax Officer, Operative Credit Society Ltd. Ward-2(1)(1), Rajkot, Aayakar Vs. Bhawan, Race Course Ring Road, Jivan Prakash, Mahila College Rajkot-360 001 Chowk, Tagore Marg, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaoas 6270 K (अपीलाथ" /Appellant) (""यथ" /Respondent) "नधा"रती क" ओर से /Assessee By : Shri Krutarth Desai, Ar राज"व क" ओर से /Revenue By :Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तार"ख/ Date Of Hearing : 03/07/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/07/2025 आदेश / O R D E R Per Dr. A.L. Saini, A.M:

For Appellant: Shri Krutarth Desai, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 142(1)Section 143(3)Section 250Section 56Section 80P(2)(a)Section 80P(2)(d)

Taxman 322 (SC), wherein amongst others, it was held that non-adherence to orders of Jurisdictional High Court and Supreme Court is a mistake apparent on record, therefore, the above orders of the jurisdictional Tribunal require rectification under section 254 (2) of the Act. In this regard, we find that

Trans Union Llc, Pune vs. Deputy Commissioner of Income Tax 4(1)(2), Mumbai

ITA 1441/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Jul 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(1)Section 154Section 250Section 9(1)(vi)

supra). The ld. AR further submitted that the subsequent decision of the Hon'ble Supreme Court is to be treated as a mistake apparent on record within the meaning of section 154 of the Act and in this regard drew our attention to Circular No. 68 (F.NO. 245/17/71-A&PAC) dated ... extract of the Circular is as under: “SECTION 154 . RECTIFICATION OF MISTAKES 899. Mistakes apparent from records - Whether can be treated as such on the basis of subsequent decision of Supreme Court 1. The Board are advised that a mistake arising as a result of a subsequent interpretation

Trans Union Llc, Pune vs. Deputy Commissioner of Income Tax 4(1)(2), Mumbai

ITA 1405/MUM/2025[2018-19]Status: DisposedITAT Mumbai17 Jul 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(1)Section 154Section 250Section 9(1)(vi)

supra). The ld. AR further submitted that the subsequent decision of the Hon'ble Supreme Court is to be treated as a mistake apparent on record within the meaning of section 154 of the Act and in this regard drew our attention to Circular No. 68 (F.NO. 245/17/71-A&PAC) dated ... extract of the Circular is as under: “SECTION 154 . RECTIFICATION OF MISTAKES 899. Mistakes apparent from records - Whether can be treated as such on the basis of subsequent decision of Supreme Court 1. The Board are advised that a mistake arising as a result of a subsequent interpretation

Trans Union Llc, Pune vs. Deputy Commissioner of Income Tax 4(1)(2), Mumbai

ITA 1404/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Jul 2025AY 2017-18

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(1)Section 154Section 250Section 9(1)(vi)

supra). The ld. AR further submitted that the subsequent decision of the Hon'ble Supreme Court is to be treated as a mistake apparent on record within the meaning of section 154 of the Act and in this regard drew our attention to Circular No. 68 (F.NO. 245/17/71-A&PAC) dated ... extract of the Circular is as under: “SECTION 154 . RECTIFICATION OF MISTAKES 899. Mistakes apparent from records - Whether can be treated as such on the basis of subsequent decision of Supreme Court 1. The Board are advised that a mistake arising as a result of a subsequent interpretation

Trans Union Llc, Pune vs. Deputy Commissioner of Income Tax 4(1)(2), Mumbai

ITA 1403/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Jul 2025AY 2016-17

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Rajan Vora, Shri NikhilFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(1)Section 154Section 250Section 9(1)(vi)

supra). The ld. AR further submitted that the subsequent decision of the Hon'ble Supreme Court is to be treated as a mistake apparent on record within the meaning of section 154 of the Act and in this regard drew our attention to Circular No. 68 (F.NO. 245/17/71-A&PAC) dated ... extract of the Circular is as under: “SECTION 154 . RECTIFICATION OF MISTAKES 899. Mistakes apparent from records - Whether can be treated as such on the basis of subsequent decision of Supreme Court 1. The Board are advised that a mistake arising as a result of a subsequent interpretation

Deputy Commissioner of Income Tax, Circle-2(1)(1), Vadodara vs. M/S. Sun Pharmaceuticals Industries Ltd, Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1785/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2009-10

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

For Appellant: Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274

erred in initiating the rectification proceedings and passing the order u/s.154 of the Act as: 2.1.1 There was no mistake apparent on record; 2.1.2 The issue involved was highly legal and debatable in nature; 2.1.3 It was merely based on change of opinion. 2.2 The Ld. CIT(A) erred

Sun Pharmaceuticals Industries Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Central Circle-2(1)(1), Baroda

In the result, the appeal filed by the Assessee in ITA No

ITA 1750/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2009-10

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274

erred in initiating the rectification proceedings and passing the order u/s. 154 of the Act as: 2.1.1 There was no mistake apparent on record; 2.1.2 The issue involved was highly legal and debatable in nature; 2.1.3 It was merely based on change of opinion. ITA Nos.1741 & 1750/Ahd/2019 (by Assessee

Sun Pharmaceuticals Industries Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Central Circle-2(1)(1), Baroda

In the result, the appeal filed by the Assessee in ITA No

ITA 1741/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2009-10

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274

erred in initiating the rectification proceedings and passing the order u/s. 154 of the Act as: 2.1.1 There was no mistake apparent on record; 2.1.2 The issue involved was highly legal and debatable in nature; 2.1.3 It was merely based on change of opinion. ITA Nos.1741 & 1750/Ahd/2019 (by Assessee

Sri Akshiya Shiradi Saibaba Trust, Pondcherry vs. ITO, Pondicherry

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

ITA 198/CHNY/2025[2021-22]Status: DisposedITAT Chennai04 Jul 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.P.M.Kathir, Advocate for Mr.T.Vasudevan, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 11Section 12A(1)(b)Section 139(1)Section 143(1)Section 154Section 250

action and asserted that it has filed Form 10B on 11.01.2022 and the RoI on 12.01.2022 and reiterated that there was no mistake apparent on record and prayed for dropping the proposed 154 proceedings; and simultaneously filed petition for condonation of delay u/s.119(2) of the Act before the Ld.CIT

F5 Networks Innovation Private Limited, Hyderabad vs. Income Tax Officer, Ward-17(1), Hyderabad

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

ITA 912/HYD/2024[2020-21]Status: DisposedITAT Hyderabad30 Jun 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Sharath Rao & ShriFor Respondent: Shri Narender Kumar Naik
Section 143(1)Section 143(3)Section 92C

thereby carry forward the disallowance of exemption claimed u/s.10AA of the Act. It was submitted that, this was a mistake apparent on record and the Ld. AO’s findings support the admissibility of the deduction. Accordingly, the Ld. AR prayed before the bench to delete the addition made

Maya Sikshan Prashikshan Sansthan, Mendu Road Hathras vs. Income Tax Officer, Hathras

In the result, the appeal of the assessee is allowed

ITA 559/AGR/2024[2019-20]Status: DisposedITAT Agra24 Jun 2025AY 2019-20

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwalincome Tax Officer, Maya Sikshan Ward-(3)(4), Prashikshan Sansthan, Vs. Hathras. Ravinder Singh Prakash Textile Compound, Mendu Road, Hathras-204101 Pan-Aaabm5383N (Appellant) (Respondent)

Section 10Section 139(4)Section 143(1)Section 154Section 250

Addl./Jt. CIT, Patna vide impugned order has dismissed the appeal by holding that there is no mistake apparent on record in the order passed by the CPC and, therefore, the rectification application filed u/s 154 has rightly been dismissed by CPC and, accordingly, the appeal of the assessee

Haneda Trading and Construction Sdn Bhn, West Malaysia vs. DCIT, International Taxation, Circle-1(2), Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 2073/CHNY/2024[2014-15]Status: DisposedITAT Chennai23 Jun 2025AY 2014-15

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1072 & 2073/Chny/2024 िनधा"रण वष"/Assessment Year:2014-15 Haneda Trading & The Deputy Commissioner Construction Sdn Bhd, Vs. Of Income Tax, Suite 10-01 Subang Square, Circle 1(2), Corporate Tower, Chennai. 47500, Jalan Ss, 15/4G, Subang Jaya Selangor, West Malaysia Pan: Aagch 2363G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाई क" तारीख/Date Of Hearing : 17.06.2025 घोषणा क" तारीख/Date Of Pronouncement : 23.06.2025

For Appellant: Shri Arjun Raj, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 144(1)(a)Section 144CSection 144C(13)Section 148Section 154Section 250Section 56(2)(vii)

made by the AO. Thereafter the CIT(A) rectified his original order u/s.154 of the Act on 21.06.2024 by stating there is a mistake apparent on record with regard to the valuation of FMV of shares subscribed by the assessee company and reconfirmed the addition made by the AO u/s.56

Haneda Trading and Construction Sdn Bhd, West Malaysia vs. DCIT, International Taxation, Circle-1(2), Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 1072/CHNY/2024[2014-15]Status: DisposedITAT Chennai23 Jun 2025AY 2014-15

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1072 & 2073/Chny/2024 िनधा"रण वष"/Assessment Year:2014-15 Haneda Trading & The Deputy Commissioner Construction Sdn Bhd, Vs. Of Income Tax, Suite 10-01 Subang Square, Circle 1(2), Corporate Tower, Chennai. 47500, Jalan Ss, 15/4G, Subang Jaya Selangor, West Malaysia Pan: Aagch 2363G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाई क" तारीख/Date Of Hearing : 17.06.2025 घोषणा क" तारीख/Date Of Pronouncement : 23.06.2025

For Appellant: Shri Arjun Raj, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 144(1)(a)Section 144CSection 144C(13)Section 148Section 154Section 250Section 56(2)(vii)

made by the AO. Thereafter the CIT(A) rectified his original order u/s.154 of the Act on 21.06.2024 by stating there is a mistake apparent on record with regard to the valuation of FMV of shares subscribed by the assessee company and reconfirmed the addition made by the AO u/s.56