“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

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.

Laxmndas Bhatia Hingwala Pvt. Ltd. v. Asst. CIT

330 ITR 243 · 2011 · High Court

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

Sterling Court F Wing Co Op Housing Society Limited, Mumbai vs. Income Tax Officer Ward 31(2)(1), Mumbai

ITA 7122/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Jan 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Vijay Shah, ARFor Respondent: Assessee by

Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 80ASection 80A(5)Section 80PSection 80P(2)(d)

deduction under section 80P(2)(d) for Rs. 2,66,556/-. Being aggrieved with such disallowance, assessee preferred to file an application for rectification under section 154 of the Act before the Jurisdictional AO (JAO), but JAO rejected the request of assessee Sterling Court F Wing Co-op. Housing Society ... exemption claimed under section 80P(2)(d) in processing of return under section 143(1) of the Act and thereafter rejection of rectification under section 154 was not in accordance with the settled principle of law. The assessee herein is entitled for the claim of deduction under section

Sterling Court F Wing Co -Op. Housing Society Limited, Mumbai vs. Income Tax Officer Ward 31(2)(1), Mumbai

ITA 7121/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Jan 2026AY 2012-13

Bench: Shri Pawan Singh, Jm &

For Appellant: ITA Nos. 7121, 7120 &

Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 80ASection 80A(5)Section 80PSection 80P(2)(d)

deduction under section 80P(2)(d) for Rs. 2,66,556/-. Being aggrieved with such disallowance, assessee preferred to file an application for rectification under section 154 of the Act before the Jurisdictional AO (JAO), but JAO rejected the request of assessee ITA Nos. 7121, 7120 & 7122/Mum/2025 Sterling Court ... exemption claimed under section 80P(2)(d) in processing of return under section 143(1) of the Act and thereafter rejection of rectification under section 154 was not in accordance with the settled principle of law. The assessee herein is entitled for the claim of deduction under section

Sterling Court F Wing Co Op Housing Society Limited, Mumbai vs. Income Tax Officer Ward 31(2)(1), Mumbai

ITA 7120/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Jan 2026AY 2013-14

Bench: Shri Pawan Singh, Jm &

For Appellant: ITA Nos. 7121, 7120 &

Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 80ASection 80A(5)Section 80PSection 80P(2)(d)

deduction under section 80P(2)(d) for Rs. 2,66,556/-. Being aggrieved with such disallowance, assessee preferred to file an application for rectification under section 154 of the Act before the Jurisdictional AO (JAO), but JAO rejected the request of assessee ITA Nos. 7121, 7120 & 7122/Mum/2025 Sterling Court ... exemption claimed under section 80P(2)(d) in processing of return under section 143(1) of the Act and thereafter rejection of rectification under section 154 was not in accordance with the settled principle of law. The assessee herein is entitled for the claim of deduction under section

Satara Engineering Projects and Equipments Private Limited, Satara vs. Deputy Commissioner of Income Tax, Circle, Satara

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

ITA 2450/PUN/2025[2024-25]Status: DisposedITAT Pune06 Jan 2026AY 2024-25

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2450/Pun/2025 Assessment Year : 2024-25

For Appellant: Shri Ashwani Kumar &For Respondent: Shri Ganesh B. Budruk

Section 115BSection 139(1)Section 143(1)Section 250

applying the tax rate of 22% under section 115BAA instead of 15% under section 115BAB. Although, an application for rectification under section 154 was also filed by the appellant, but CPC rejected it on 03.06.2024, upholding the earlier adjustment. Hence, the present appeal u/s 250(6). 7.1.1. I have carefully

Sri Shivaganga Yoga Centre, Shivamogga vs. Income Tax Officer(Exemptions), Ward-1, Hubli

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

ITA 1044/BANG/2025[2019-20]Status: DisposedITAT Bangalore22 Dec 2025AY 2019-20

Bench: Shri Prashant Maharishiassessment Year : 2019-20

For Appellant: Shri Gowrish, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel

Section 10Section 11Section 143Section 154

reason that the issue raised in application under section 154 of the act are debatable one and are beyond the scope of rectification under section 154 of the act. Aggrieved with the rejection of above rectification application assessee preferred an appeal before the learned CIT – A who disposed ... rejected for the reason that issue raised in application under section 154 which are debatable one and are beyond the scope of rectification under section 154 of the income tax act and therefore same was rejected. 6. The learned CIT-A held that the central processing Centre has correctly disallowed

Punchsheel Nursing Home, Main Road Nagrota Bagwan vs. ITO TDS Ward 76(3), Aayakar Bhawan, Distt Centre Laxmi Nagar

In the result, both the appeals of the assessee are allowed

ITA 3321/DEL/2025[2013-14]Status: DisposedITAT Delhi19 Dec 2025AY 2013-14

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 154Section 201Section 220(2)Section 234E

under section 220(2) was created against the assessee under the Income Tax Act 1961 wad charged. That thereafter the assessee filed online rectification under section 154 of the Income Tax Act 1961 and the said demand was not rectified and demand

Punchsheel Nursing Home, Main Road Nagrota Bagwan vs. ITO TDS Ward 76(3), Aayakar Bhawan Distt Centre Laxmi Nagar

In the result, both the appeals of the assessee are allowed

ITA 3320/DEL/2025[2015-16]Status: DisposedITAT Delhi19 Dec 2025AY 2015-16

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 154Section 201Section 220(2)Section 234E

Sharus Steel Products Private Limited, Mumbai vs. ITO, Ward 2(3)(1), Mumbai

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

ITA 4903/MUM/2025[2024-25]Status: DisposedITAT Mumbai15 Dec 2025AY 2024-25

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2024-25

For Respondent: Mr. Dharmesh Shah/

Section 115BSection 115JSection 143(1)Section 250

assessee electronically filed the correct Form No. 10 electronically filed the correct Form No. 10-IC on 30.01.2025 IC on 30.01.2025 and sought rectification under section 154 by filing a revised return on sought rectification under section 154 by filing a revised return on sought rectification under section 154

Vinayaka Education Trust, Nadiad vs. The DDIT, CPC, Bengaluru Juris. AO- the ITO, Exemption Ward, Vadodara

In the result, the appeal of the assessee stands allowed

ITA 1402/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2021-22

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Shri Chetan Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 10Section 11Section 11(1)Section 11(1)(a)Section 12ASection 143(1)Section 154Section 250

demand of Rs.1,87,34,360/- was raised. 2.3 Aggrieved by the intimation under section 143(1), the assessee filed an application for rectification under section 154, however, the CPC passed the order dated 06.03.2023 under section 154 reiterating the same computation as in the intimation under section

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

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

ITA 2218/DEL/2025[2019-20]Status: DisposedITAT Delhi05 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

under section 234A of the Act. (ii) That the re-computation of interest under section 234A may at most be a matter of rectification under section 154 of the Act, not of revision under section 263 of the Act. 7. At the time of hearing, ld. AR of the assessee

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

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

ITA 2217/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

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

ITA 2216/DEL/2025[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption, Exemption Ward

In the result the appeal filed by the assessee in ITA

ITA 1785/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Appellant Respondent Pan: Aabtb1496N Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa

Section 11Section 12ASection 143(1)

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

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption

In the result the appeal filed by the assessee in ITA

ITA 1783/PUN/2025[2021-22]Status: DisposedITAT Pune28 Nov 2025AY 2021-22

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan | Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Pan: Aabtb1496N Appellant Respondent Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa

Section 11Section 12ASection 143(1)

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption, Exemption Ward

In the result the appeal filed by the assessee in ITA

ITA 1782/PUN/2025[2022-23]Status: DisposedITAT Pune28 Nov 2025AY 2022-23

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Pan: Aabtb1496N Appellant Respondent Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa

Section 11Section 12ASection 143(1)

Kae Capital Fund, Mumbai vs. ITO Ward 25(1)(1), Mumbai

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

ITA 3752/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Nov 2025AY 2020-21

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailkae Capital Fund, 74Ab, Jolly Maker Chambers Ii, Vinay Shah Marg, Mumbai – 400021 ............... Appellant Pan : Aabtk9875E V/S Income Tax Officer, Ward – 25(1)(1)., ……………… Respondent Kautilya Bhavan, Bkc, Mumbai

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Hemanshu Joshi, Sr.DR

Section 10Section 10(35)Section 115USection 143(1)Section 154Section 250

exempt income. The learned AR submitted that against the aforesaid intimation issued under section 143(1) of the Act, the assessee filed a rectification under section 154 of the Act, pointing out the correct exempt income earned by the assessee amounting to Rs.1,65,59,461/- claimed as exempt under

Discovery Digital Network Private Limited, Nashik vs. Assistant Commissioner of Income Tax, Circle 1, Nashik

ITA 2886/PUN/2024[2014-15]Status: DisposedITAT Pune21 Nov 2025AY 2014-15

For Appellant: Shri Nimesh VoraFor Respondent: Shri Vidya Ratan Kishore

Section 139(4)Section 143(3)Section 154Section 23Section 234DSection 244A

return of income; (ii) a decision on debatable point of law cannot be regarded as mistake apparent from record amenable for rectification under section 154 of the Act, and (iii) tax authorities cannot take advantage of any error or mistake committed in return of income out of the assessee ... appreciating the fact that the decision on a debatable point of law cannot be regarded as a mistake apparent from record amenable for rectification under section 154; 5.1 In favour of the above grounds the appellant has submitted Section 154 of the Act, inter-alia empowers the tax officer

Highradius Technologies Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -2(1), Hyderabad

ITA 436/HYD/2024[2020-21]Status: HeardITAT Hyderabad12 Nov 2025AY 2020-21

Bench: Us:

Section 143(1)Section 143(3)Section 144B

आयकर अपील"य "याया"धकरण म", हैदराबाद ‘ए’ ब"च, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench

S H Kelkar and Company Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(3)(1), Mumbai

The appeal is partly allowed

ITA 5591/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Nov 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Shri Prabhash Shankar: A.Y : 2011-12

For Appellant: Shri Saurabh BhatFor Respondent: Shri Swapnil Choudhary

Section 140ASection 143(1)Section 143(3)Section 154Section 244ASection 4(2)

dismissing the appeal as “deemed to be withdrawn and infructuous”, particularly when the dispute arising out of order dated 28.05.2018 in application for rectification under Section 154 of the Act was not sought to be settled under the VSVS. The learned counsel has placed reliance on the decision of this

Purnima Singh, Ratlam vs. Assistant Director of Income Tax, CPC - Bengaluru

Appeal is allowed for statistical purpose

ITA 301/IND/2025[2021-22]Status: DisposedITAT Indore07 Nov 2025AY 2021-22

Bench: Shri B.M. Biyani

Section 139Section 139(1)Section 139(5)Section 143(1)Section 154Section 44ASection 80Section 801B

furnished with the return, then the deduction may be disallowed as a prima facie adjustment. But, if evidence is subsequently furnished, rectification under Section 154 should be carried out to the extent permitted by the Board Circular No. 669, dated October ... provision of the Act is not specifically mentioned in the Board circular. 10. The assessee would be entitled to the deductions in the rectification under Section 154 to the extent permitted by the Board Circular No. 669, dated October 25, 1993 (see [1993] 204 ITR (St.) 105). The Assessing Officer