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“rectification under section 154”

Rectification & RevisionSection 154Section 154322 judgments

The decision most relied on for rectification under section 154 is ACIT v. Saurashtra Kutch Stock Exchange Ltd. (305 ITR 227), cited in 470 judgments on BharatTax.

Leading authorities on rectification under section 154

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.

Mavilayi Service Co-operative Bank Ltd. v. CIT
414 ITR 67 · 2019 · High Court
190
citing judgments

The Full Bench of the Kerala High Court held that a co-operative bank or society is not entitled to a deduction under Section 80P(2)(a)(i) of the Income-tax Act if it provides loans to non-members. This decision was subsequently overruled by the Supreme Court.

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.

Laxmndas Bhatia Hingwala Pvt. Ltd. v. Asst. CIT
330 ITR 243 · 2011 · High Court
49
citing judgments

An order cannot be amended under Section 254(2) of the Income-tax Act, 1961, if it involves debatable issues of fact or law. The power under this section is restricted to rectifying mistakes apparent from the record.

Judgments citing rectification under section 154

Mohammedaltaf Abdulkadar Memon, Surat vs. Income Tax Officer, Ward-2(2)(1) and DCIT, CPC, Surat

In the result, the grounds of appeal raised by the assessee are allowed

ITA 151/SRT/2023[2016-17]Status: DisposedITAT Surat27 Jun 2023AY 2016-17

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Mohammedaltaf Abdulkadar Memon, I.T.O. 4/4478 Taiyabi Street, Ward- 2(2)(1), Vs. Zampa Bazar, Surat & Dcit, Cpc Surat-395003. Bangalore) Pan: Ahzpm 3224 E Appellant Respondednt

Section 143(1)Section 154Section 234BSection 254(1)Section 44A

while processing the return of income, not allowed deduction of depreciation of Rs. 40,06,642/- on vehicles. The assessee filed application for rectification under section 154 dated 11/10/2018. The request/application for rectification was turn down/dismissed vide intimation dated 11/12/2018. In the reasons for rectification, the C.P.C. intimated that depreciation

Shree Saurastra Ka;Akendra Co-Op. Housing Society Ltd., Rajkot vs. The ADIT (CPC), Bangalore

In the result, the appeal of the assessee is allowed

ITA 55/RJT/2023[2019-20]Status: HeardITAT Rajkot31 May 2023AY 2019-20

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri D. M. Rindani, A.RFor Respondent: Shri B. D. Gupta, Sr. DR
Section 143(1)Section 143(1)(a)Section 154Section 254Section 254(2)Section 80Section 80PSection 80P(2)Section 80P(2)(d)

Asst.Year –2019-20 "Further in the case of assessments under section 143(1), it is not permissible for the assesses to plead for rectification under section 154 on grounds of mistake apparent from record. In view of the decision of the Tribunal in Sixth ITO v. Pithva Engg. Works

Vertex Spinning Ltd, Mumbai vs. DCIT 5(3), Mumbai

In the result ground no. 1 and 2

ITA 353/MUM/2018[2007-08]Status: DisposedITAT Mumbai15 May 2023AY 2007-08

Bench: Shri Amit Shukla & Shri Gagan Goyalm/S. Vertex Spinning Limited 1011, 10Th Floor, Embassy Centre, 207, Nariman Point, Mumbai-400 021 Pan:Aabcv5617N ...... Appellant Vs. Dcit, Circle-5(3) 573, Aayakar Bhavan, M. K. Road Mumbai-400 020 ..... Respondent

For Appellant: Smt. Dinkle HariyaFor Respondent: Vranda U Matkari,Sr. AR
Section 115JSection 142(1)Section 143(3)Section 148Section 154Section 250

will not be open to the Assessing Officer to arbitrarily or wantonly resort to the provisions of section 147 where the process of rectification under section 154 fails on the merits.” 7. As observed matter was duly covered by section 154 of the Act and AO thrice got the opportunity

Brij Gopal Construction Co. P.Ltd, Delhi vs. DCIT, Central Circle-3, New Delhi

In the result, we see no infirmity in the judgment of the High Court

ITA 2123/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Apr 2023AY 2018-19

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Ms. Monika Agarwal, AdvFor Respondent: Sh. Kanv Bali, Sr. DR
Section 143Section 143(1)Section 143(1)(a)Section 143(2)Section 154Section 2(24)(x)Section 36(1)(va)Section 43B

objection to any of the orders made by the Assessing Officer determining the income, it is open to the assessee to ask for rectification under Section 154. Apart therefrom, the provisions of Section 143(1)(a)(i) indicate that the intimation sent under Section 143(1)(a) shall be without

Rajkamal Overseas, Delhi vs. ITO, Ward 63(1), New Delhi

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

ITA 38/DEL/2023[2020-21]Status: DisposedITAT Delhi26 Apr 2023AY 2020-21

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Pratap Gupta, CAFor Respondent: Shri Om Parkash, Sr.DR
Section 143(1)Section 154Section 40Section 40b

application under Section 154 dated 17.11.2022 seeking rectification of mistake while processing intimation under Section 143(1) and reversal of the disallowance. The rectification under Section 154 was however passed by the AO (CPC) reiterating the adjustments and without any relief. 3. Aggrieved by the denial of rectification, the assessee

Girnar Software Private Limited, 6Th Floor, Jaipur Textile Market, B-2 Near Model Town, Malviya Nagar Jaipur vs. ACIT, Circle 4, Jaipur

ITA 428/JPR/2022[2016-17]Status: DisposedITAT Jaipur05 Apr 2023AY 2016-17

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Yogesh Parwal, CA and Shri P.C. Parwal, C.AFor Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(1)Section 143(3)Section 244A

June 2019 in its bank account i.e. after 6 months of passing of assessment order. 2.1 The Appellant filed an application for rectification under section 154 of the Act with the AO and requested to grant interest under section 244A till the date of actual grant of refund amount

Indigo Infraprojects Private Limited, Delhi vs. ACIT, Circle 10(1), Delhi

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

ITA 1887/DEL/2022[2019-20]Status: DisposedITAT Delhi16 Mar 2023AY 2019-20

Bench: Shri Kul Bharat & Shri O.P.Kant[Assessment Year : 2019-20] Indigo Infraprojects Pvt.Ltd., Vs Acit, Wz-13, D/2, Opposite A-2, Circle-10(1), Gurudwara, Asaltpur, Janakpuri, Delhi. Delhi-110058. Pan-Aacci8551P Appellant Respondent Appellant By Shri Tarun Kandhari, Ca & Ms. Renu Suri, Ca Respondent By Shri Anuj Garg, Sr.Dr Date Of Hearing 15.03.2023 Date Of Pronouncement 16.03.2023

Section 143(1)Section 154Section 192Section 199Section 36(1)(va)

return of income, in accordance with section 199 read with rule 37BA of the Income Tax Act, 1961. So, the appellant filed the rectification under section 154 of the Income Tax Act, 1961 against the intimation order under section 143(1) of the Income Tax Act, 196f. But CPC again

Sumedha Arora, Delhi vs. ITO, Ward-67(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1399/DEL/2022[2019-20]Status: DisposedITAT Delhi15 Mar 2023AY 2019-20

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Saurbh Jindal, CAFor Respondent: Shri Abhishek Kumar, Sr.DR
Section 154Section 90Section 90(2)

issued by the Income Tax Department wherein the benefit of FTC claimed against salary earned in Italy was denied. The assessee sought rectification under Section 154 of the Act vide application dated 02.04.2021. A rectification order dated 22.05.2021 was issued maintaining the original position and thus the foreign tax credit ... Tribunal also observed that issue of allowability of FTC is not a debatable issue and only one view is possible and thus seeking rectification under Section 154 could be resorted by the assessee. Similar view has been taken in ‘42 Hertz Software India Pvt. Ltd. vs. ACIT,’ ITA No.29/Bang/2021 order

Smt. Dinumatiben Damjibhai Shilu, Rajkot vs. The Income Tax Officer, Ward-2 (2) (5), Rajkot

The appeal of the assessee is allowed

ITA 195/RJT/2022[2014-15]Status: DisposedITAT Rajkot28 Feb 2023AY 2014-15

Bench: SMT.ANNAPURNA GUPTA (Accountant Member), SMT. MADHUMITA ROY, JUDICIAL MEMBER (Judicial Member)

For Appellant: Shri D.M. Rindani, ld.ARFor Respondent: Shri B.D.Gupta, Ld.Sr.DR
Section 143Section 143(1)Section 154Section 250(6)Section 80CSection 89(1)

receiving intimation, and which mistake on merits the AO admitted to also, we find no reason for rejecting the assessee’s claim of rectification under section 154 of the Act. Even otherwise, CBDT vide its Circular No.014(XL-35)/1955 dated 11.4.1955 has long back laid down the duty

M/S. Grid Corporation of Orissa Limited, Bhubaneswar vs. ACIT-(TDS), Bhubaneswar

In the result, appeal of the assessee stands allowed

ITA 323/CTK/2019[2009-10]Status: DisposedITAT Cuttack20 Feb 2023AY 2009-10

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2009-2010 2010 Grid Corporation Of Orissa Grid Corporation Of Orissa Vs. Acit (Tds), Acit (Tds), Ltd., Ltd., Gridco Gridco House, House, Bhubaneswar. Bhubaneswar. Janapath, Bhubaneswar. Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 12.7.2019 In Appeal No. In Appeal No.0035/17-18 For The Assessment Year The Assessment Year 2009-2010. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

For Appellant: S/Shri Ved Jain/P.Venugopal RaoFor Respondent: Shri M.K.Gautam
Section 154Section 244ASection 244A(2)

Strips Ltd. (11 taxmann.com 361) has held that overlooking of statutory provision is clearly a mistake apparent on record, and on that basis, rectification under section 154 is clearly admissible. In said case, assessment of the assessee company for the assessment year 1985-86 was completed. Thereafter, the Assessing Officer ... allowed overlooking section 8OVVA of the Act. Overlooking of a statutory provision is clearly a mistake apparent on record and on that basis, rectification under section 154 of the Act was clearly admissible. Impermissibility of deduction is not debatable if section 80VVA is applied. This being

O P Marine Services Private Limited, Gandhidham-Kutch vs. The ITO, Ward-2, Gandhidham-Kutch

In the result, appeal filed by the assessee is dismissed

ITA 279/RJT/2022[2018-19]Status: DisposedITAT Rajkot10 Feb 2023AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Ms. Astha Maniyar, ARFor Respondent: Shri B.D. Gupta, Sr. DR
Section 139Section 143(1)Section 154Section 36(1)(va)

contribution as well and was the aggregate contribution to PF. Employee’s share was only Rs.11,53,536/-. Therefore, the assessee filed rectification under Section 154 of the Act which was rejected vide order dated 03.06.2020 4. Being aggrieved by the order dated 03.06.2020 passed under Section 154

M/S Beyond Key Systems P Ltd, Indore vs. The DCIT/ACIT 1(1), Indore

ITA 184/IND/2022[2018-19]Status: DisposedITAT Indore19 Jan 2023AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shrib.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2018-19 M/S Beyond Key Systems Dcit/Acit-Circle,1(1) Private Ltd. Indore बनाम/ Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Aaccb 7622 G Assessee By Shri Manish Dafaria, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 03.01.2023 Date Of Pronouncement 19.01.2023

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 40A(7)Section 43BSection 44A

objection to any of the orders made by the Assessing Officer determining the income, it is open to the assessee to ask for rectification under Section 154. Apart therefrom, the provisions of Section 143(1)(a)(i) indicate that the intimation sent under Section 143(1)(a) shall be without

Nirav Bipinbhai Vaghasiya, Surat vs. Income Tax Officer, Ward 3(2)(1), Surat

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

ITA 90/SRT/2022[2018-19]Status: DisposedITAT Surat16 Jan 2023AY 2018-19

Bench: Shri Pawan Singhआ.अ.सं./Ita No.90/Srt/2022 (Ay 2018-19) (Hearing In Physical Court) Nirav Bipinbhai Vaghasiya Income Tax Officer, 59, Shradha Deep Society, Ward-3(2)(1), Surat Vs Singanpore, Causewayroad, Ved Road, Surat-395004 Pan No: Amupv 4454 H अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By None राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing 04.01.2023 उ"घोषणा क" तार"ख/Date Of 16.01.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Nfac”/Ld.Cit(A) Dated 28.12.2021 For Assessment Year 2018-19, Which In Turn Arises Out Assessment Order Passed By Asst. Director Of Income Tax, Centralized Processing Centre (Cpc) Bengaluru Under Section 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 23.10.2019. The Assessee Has Raised The Following Grounds Of Appeal:- “1. In Law & In Facts & Circumstances Of The Case, The Learned Cit(A) National Faceless Appeal Centre Erred In Not Allowing Tds Nirav B Vaghasiya Credit Of Rs.2,21,000 Though The Same Is Duly Reflected In Form No 26As Of The Appellant. 1.1 In Law & In Facts & Circumstances Of The Case, The Learned Cit(A) National Faceless Appeal Centre Erred In Not Allowing The Tds Credit Of Rs.2,21,000 Though The Capital Gain On Sale Of Property Was Offered For Taxation In The Hands Of Partnership Form & No Revenue Loss Incurred To The Department. 1.2 In Law & In Facts & Circumstances Of The Case, The Learned Cit(A) National Faceless Appeal Centre Erred In Not Allowing Tds Credit To The Appellant Though No Income Against Such Tds Credit Was Earned By The Appellant Against Such Tds Credit.

Section 143(1)Section 154Section 194ISection 254(1)

refund of TDS reflected in his Form-26AS. the CPC denied such refund in its intimation dated 08.10.2018. The assessee filed application for rectification under section 154. In the application under section 154, the assessee claimed such refund on the ground that during the financial year, immovable property was sold

Bhaskar Dutta, New Delhi vs. DCIT, Int. Taxation 1(2)(2), New Delhi

In the result, the appeal is allowed

ITA 1869/DEL/2022[2020-21]Status: DisposedITAT Delhi11 Jan 2023AY 2020-21

Bench: Shri G.S. Pannu & Shri Saktijit Deyassessment Year: 2020-21

Section 143(1)Section 154Section 89

filed within the period prescribed under Rule 128 and secondly, the issue being a debatable one, cannot be a subject matter of rectification under Section 154 of the Act. At the outset, we will address the issue of limitation in filing Form 67. No doubt, as per the extant Rule

Prime Health Care Products, Daman vs. ACIT, Vapi Circle, Vapi

In the result, appeal filed by the assessee is dismissed

ITA 506/SRT/2019[2009-10]Status: DisposedITAT Surat06 Jan 2023AY 2009-10

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.506/Srt/2019 "नधा"रणवष"/Assessment Year: (2009-10) (Virtual Court Hearing) Prime Health Care Products, Vs. The Dcit, Vapi Circle, Plot No.198 To 207, Dabhel Indl. Co. Vapi. Society Ltd., Village. Dabhel, Daman, Daman-396210. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfp6232C

Section 143(3)Section 154Section 80I

assessment order. The assessee has requested the assessing officer to allow this claim of deduction under section 80IB of the Act, by doing rectification under section 154 of the Act. That is, assessee wanted to correct the mistake in the original order passed by assessing officer under section ... cannot be rectified under section 154 of the Act. Besides, ld DR also stated that assessee filed the appeal against the order of rectification under section 154 of the Act, therefore assessee`s appeal should not be allowed on merit. 10. We have heard both the parties and carefully gone

Sree Gokulam Chit and Finance Co. Pvt. Ltd., Chennai vs. Dy. Commissioner Income Tax, Central Circle-1(2), Chennai

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

ITA 765/CHNY/2022[2020-21]Status: DisposedITAT Chennai21 Dec 2022AY 2020-21

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri N Arjunraj, CA for Shri S. Sridhar, AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 1Section 143(1)Section 36Section 36(1)(va)

case of South Industrial Corporation Ltd., (2002) 258 ITR 481, wherein it is held as “When a statutory provisions is record. The rectification under section 154(1) on the ground that the order sought to be rectified is not in conformity with the law declared by the apex court

Shree Bhairav Seva Samiti, Mumbai vs. Income Tax Officer(Exexmption), Thane

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

ITA 2225/MUM/2022[2016-17]Status: DisposedITAT Mumbai08 Dec 2022AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Himanshu GandhiFor Respondent: Ms. Richa Gulati
Section 11Section 12(1)(b)Section 12ASection 139(4)Section 143(1)Section 154Section 250

taxable income. On receipt intimation under section 143(1) of the Act the assessee uploaded in Form 10B and filed application for rectification under section 154 of the Act. The application of the assessee was rejected on the ground report in Form 10B was not furnished before due date

Petronet Mhb Limited, Bangalore vs. The Income Tax Officer, Ward-5(1)(3), Bangalore

In the result, both the appeal of the assessee is allowed

ITA 789/BANG/2022[2013-14]Status: DisposedITAT Bangalore28 Nov 2022AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Shri M.G Vinay Simha, C.AFor Respondent: Shri K.R Narayana, Addl. CIT (DR)
Section 143(3)Section 154Section 37(1)

Officer was wrong in passing order u/s. 154 on an issue which requires debate and discussion, it cannot become a subject-matter of rectification under section 154 of the Act because under this section only patent and obvious mistakes of law and facts can be rectified. It is not open

Shri Sambhavnath Swetamber Jain Derasar Trust, Palghar vs. CIT(A), Thane

ITA 926/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Sept 2022AY 2017-18

Bench: Shri Kuldip Singhassessment Year: 2017-18

For Appellant: Shri Zenith Jain, A.RFor Respondent: Shri Azhar Zain Vayal Parambath, D.R
Section 119(2)(b)Section 12ASection 139Section 154

amount accumulated. The Assessing Officer (AO) disallowed total deduction to the tune of Rs.3,75,794/-. Assessee trust moved an application for rectification under section 154 of the Act which was dismissed. 3. Assessee carried the matter before the Ld. CIT(A) by way of filing appeal against the order

K Ranadheer Reddy, Cuddapah vs. The Deputy Commissioner of Income Tax, Central Circle-2(1), Bangalore

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

ITA 264/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Sept 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S.Shri Kasireddy Ranadheer Reddy Vs Dcit, Central Circle - 2(1) No.5/19, Kuravapalli (V) C.R. Building, Queen'S Road T. Sundupalli, Cuddapah 516214 Bengaluru 560001 Andhra Pradesh Pan – Amcpr4790E (Appellant) (Respondent) Assessee By: Shri Shivprasad Reddy, Itp Revenue By: Smt. Priyadarshini Baseganni

For Appellant: Shri Shivprasad Reddy, ITPFor Respondent: Smt. Priyadarshini Baseganni
Section 115BSection 132Section 143(3)Section 153CSection 154Section 156Section 270ASection 271ASection 69Section 69A

accidental 7 Shri Kasireddy Ranadheer Reddy omission by inadvertence to be termed as prima facie mistake apparent from record for the purpose of rectification under Section 154 of the Act. 10. We also notice that the assessee during the course assessment has denied the ownership of the loose sheets found