rectification under section 154 — 322 judgments | BharatTax

DE vs. THAN TRUST,VADODARAVS.THE ITO, WARD- EXEMPTION, VADODARA

The appeal of the assessee is allowed

ITA 1729/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2016-17

Bench: Ms. Suchitra Kamble

For Appellant: Shri Parin S Shah, ARFor Respondent: Shri Umesh Kumar Agarwal, Sr. D.R

Section 11Section 119(2)(b)Section 12ASection 143(1)Section 154Section 234A

Income Tax Act, 1961 dated 21.02.2018 thereby rejecting the said claim by the Revenue. Thereafter, the assessee trust filed rectification under Section 154 of the Act and subsequently filed Form 10B along with condonation of delay application under Section 119(2)(b) of the Act. 4. The PCIT (Exemption) rejected

ITO, AHMEDABAD vs. UDAYAN MANDAVIA, AHMEDABAD

In the result, the appeal filed by the Department is dismissed

ITA 154/AHD/2026[2017-18]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Sudhakar Verma, Sr. DRFor Respondent: Shri Palak Pavagadhi, AR

Section 115BSection 144BSection 147Section 154Section 69A

issue is debatable in nature and therefore cannot be rectified under section 154 of the Act. The CIT(Appeals) further observed that rectification under section 154 of the Act can be carried out only in respect of a mistake apparent from record and not on issues requiring detailed examination

AMITH VISHNAV GUDIMELLA,HYDERABAD vs. ITO, WARD-12(1), HYDERABAD, HYDERABAD

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

ITA 1705/HYD/2025[2020-21]Status: HeardITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: MS Reema Yadav, Sr. AR

Section 143(1)Section 154Section 90Section 91

also observed that the issue of allowability of FTC is not a debatable issue and only one view is possible and thus seeking rectification under Section 154 14 ITA.No.1705/Hyd./2025 could be resorted by the assessee. Similar view has been taken in 42 Hertz Software India

MRS. GAURI HIREN BHANU,MUMBAI vs. ITO WARD 17(3)(1), MUMBAI

ITA 8275/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Mar 2026AY 2022-23

Bench: Shri Anikesh Banerjee, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Hari S. Raheja, ARFor Respondent: Assessee by

Section 143(1)Section 143(3)

taxable income of the assessee. 6. Per contra, the ld. DR submitted that such errors can be rectified even if an application for rectification under section 154 would have been furnished by the assessee before the ld. AO. 7. Having considered the rival submissions, on perusal of the records

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

ITA 2194/BANG/2025[2019-2020]Status: DisposedITAT Bangalore24 Feb 2026AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Balusamy N, JCIT

Section 115BSection 143(1)Section 154Section 250Section 80G

issue involved was debatable in nature and therefore could not be treated as a mistake apparent from record for the purpose of rectification under section 154 of the Act. Accordingly, the action of CPC in not allowing the intra-head adjustment was upheld. 7.2 With regard to the deduction under

DINESH CHAND JAIN,KANPUR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, KANPUR

In the result, the appeal of the assessee is allowed

ITA 692/LKW/2025[2012-13]Status: DisposedITAT Lucknow17 Feb 2026AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2012-13 Dinesh Chand Jain, Vs. Dy. Cit, 7/189, Swaroop Nagar, Kanpur- Central Circle-1, Kanpur 280002, U.P. Pan: Adbpj2732Q (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Add Cit Dr Date Of Hearing: 04.12.2025 Date Of Pronouncement: 17.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Ao Under Section 143(3) R.W.S. 154 Of The Income Tax Act, 1961 On 28.04.2016. The Grounds Of Appeal Are As Under:- “1.1 Because The Id. "Cit(A)" Has Erred In Law & On Facts In Upholding The Action Of The Assessing Officer In Withdrawing The Refund Of Interest Amounting To Rs. 8,20,163/-, Paid To The Assessee U/S 244A Of The Income-Tax Act, 1961 On Excess Amount Of Self-Assessment Tax Paid U/S 140A Of The Act. 1.2 Because The View Taken By Id. "Cit(A)" While Upholding The Action Of The Assessing Officer Is Based On Misinterpretation Of The Provisions Of Clause (B) Of Sub-Section (1) Of Section 244A Of The Act, As Applicable At The Relevant Point Of Time. 2. Because, In Any Case & Without Prejudice To The Grounds Hereinfore, While Upholding The Action Of The Assessing Officer In Withdrawing The Interest Paid To The Assessee U/S 244A Of The Act, The Ld. "Cit(A)" Failed To Appreciate That The Issue Of Payment Of Interest On Excess Amount Paid U/S 140A Was Debatable In Nature & It Could Not Have Been Decided By Invoking The Provisions Of Section 154 Of The Act As The Same Did Not Constitute A Mistake Apparent From The Record.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Add CIT DR

Section 140ASection 143(3)Section 154Section 240Section 244Section 244ASection 244A(1)(a)Section 244A(1)(b)

interest allowed earlier under section 244A on self-assessment tax paid under section 140A was contrary to the law and its withdrawal through rectification under section 154 was a correction of an apparent mistake on record. He accordingly, dismissed the appeal of the assessee. 5. The assessee is aggrieved

DILIP VENGSARKAR FOUNDATION,MUMBAI vs. INCOME TAX OFFICER (EXEPMTION) 1(2), MUMBAI

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

ITA 7791/MUM/2025[2024-25]Status: DisposedITAT Mumbai17 Feb 2026AY 2024-25

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardilip Vengsarkar Ito(Exemption)- Foundation 1(2), A-5, Sportsfield, 9A Khan Vs. Room No. 620, 6Th Abdul Gaffar Khan Road, Floor, Cumball Hill Worli Colony, Worli, Mtnl Telephone Mumbai-400 030 Exchange Building, Pedder Road, Dr. G. S. Marg, Mumbai-400 026 Pan/Gir No. Aaatd1346G (Applicant) (Respondent) Assessee By Shri Nikhil Damle & Shri Himmat Rajput, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 17.02.2026

Section 11Section 143(1)Section 154Section 250

appellant. 17. We make it clear that we have not expressed any opinion on the merits of the issues involved in the rectification under section 154, and all contentions of both parties are left open. 18. In the result, the appeal of the assessee is allowed for statistical purposes. Order

DCIT (INTERNATIONAL TAXATION)-2, HYDERABAD vs. THOGARCHEDU SUBHA SRI, HYDERABAD

In the result, the appeal of the Revenue is dismissed

ITA 1058/HYD/2025[2023-24]Status: DisposedITAT Hyderabad11 Feb 2026AY 2023-24

For Appellant: Shri BG Reddy, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 115A(1)(a)Section 143(1)Section 154Section 90(4)Section 90(5)

delayed filing\nof Form No.67 beyond the due date under section 139(1) of the Act. It was\nfurther contended that rectification under section 154 of the Act was not\npermissible in the present case, as there was no mistake apparent from the\nrecord, since Form No.10F was admittedly

CALCUTTA NEW SCHOOL SOCIETY,KOLKATA vs. ITO, WARD 1(1), EXEMPT, , KOLKATA

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

ITA 1021/KOL/2025[2022-2023]Status: DisposedITAT Kolkata10 Feb 2026AY 2022-2023

Section 154Section 5Section 80G

accepted by CPC, which added a significant amount to the total income and raised a demand. The assessee sought rectification under Section 154, but it was denied. Aggrieved, the assessee filed an appeal before the CIT(A) which was dismissed as barred by limitation due to a 190-day delay