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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

Hindustan Spimg Engineering Private Limited, Trichy vs. Assistant Director of Income Tax, Trichy

The appeal of the assessee is allowed for statistical purposes

ITA 1344/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Aug 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Manu Kumar Giri, Jm

For Appellant: Ms. Ankita S. Shah, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 119(2)(b)Section 143(1)Section 154Section 250Section 36Section 43B

demand towards the disallowance of delay in remittance of ESI & PF. The assessee also submitted that the assessee tried to file petition for rectification under section 154 which did not go through in the Income- tax Portal. The CIT(A) dismissed the appeal stating that the delay in remitting employee

Karnataka Power Corporation Limited, Bengaluru vs. ACIT, Circle-4(1)(1), Bengaluru

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

ITA 370/BANG/2025[2019-20]Status: DisposedITAT Bangalore04 Aug 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

For Appellant: Sri V. Narendra Sharma, Ld. AdvocateFor Respondent: Sri Shivanand H. Kalakeri, Ld.CIT
Section 143Section 154Section 246ASection 250Section 253Section 36Section 43B

order of assessment passed on 30/09/2021 by initiating the proceedings under section 154 of the Act, and thereafter passed an order of rectification under section 154 r.w.s. 143[3] of the Act dated 23/01/2023 by stating that there is a short levy of interest under section 234D

Karnataka Power Corporation Limited, Bengaluru vs. ACIT, Circle-4(1)(1), Bengaluru

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

ITA 369/BANG/2025[2019-20]Status: DisposedITAT Bangalore04 Aug 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmed

For Appellant: Sri V. Narendra Sharma, Ld. AdvocateFor Respondent: Sri Shivanand H. Kalakeri, Ld.CIT
Section 143Section 154Section 246ASection 250Section 253Section 36Section 43B

order of assessment passed on 30/09/2021 by initiating the proceedings under section 154 of the Act, and thereafter passed an order of rectification under section 154 r.w.s. 143[3] of the Act dated 23/01/2023 by stating that there is a short levy of interest under section 234D

Kabiguru Path Bhaban, Kolkata vs. ITO, Exemption, Ward 1(4), Kolkata

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

ITA 1165/KOL/2025[2024-2025]Status: DisposedITAT Kolkata31 Jul 2025AY 2024-2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1165/Kol/2025 Assessment Year: 2024-25 Kobiguru Path Bhaban.………..……..…………………....Appellant 8B Tala, Bhabanath Sen Street, Shyambazar, Kol-4. [Pan: Aaetk0386P] Vs. Ito, Ward-1(4), Kolkata…………....…..………………….…..... Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Appellant. Shri Ranu Biswas, Acit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 30, 2025 Date Of Pronouncing The Order : July 31, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Dated 25.03.2025, For The Assessment Year 2024–25, Passed Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For A.Y. 2024–25 On 25.09.2024, Claiming Exemption Under Section 11 Of The Act. It Is Noted That The Audit Report Applicable In The Case Of The Assessee Was Form 10Bb, Which Was Filed On 26.12.2024. The Centralized Processing Centre (Cpc), Bengaluru, Processed The Return Under Section 143(1) Of The Act & Passed An Intimation Order Dated 28.01.2025, Disallowing Exemption Under Section 11, Citing That Form 10Bb Was Not Filed Within The Prescribed Time. Against This, The

Section 11Section 143(1)Section 154Section 250

filed on time and thus, exemption was rightly denied. However, it is submitted that the Ld. CIT(A) failed to consider the subsequent rectification under Section 154 dated 03.03.2025, where the CPC itself accepted the timely filing of Form 10BB and deleted the demand. The fact of rectification was duly

The Naval Dockyard Co Op Bank Limited, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

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

ITA 4281/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanthe Naval Dockyard Co- Vs. Dcit Circle1(3)(1), Aayakar Bhavan, Op Bank Limited Mumbai-400 020 Shahid Bhagat Singh Road Fort, Mumbai-400 023 Pan/Gir No. Aabat7232R (Applicant) (Respondent) Assessee By Shri Jayesh Kala, Ld. Ar Revenue By Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 31.07.2025 आदेश / Order Per Raj Kumar Chauhan, Jm:

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 250Section 43B

with no additional tax demand. If the appellant believes the Section 143(1) intimation's disallowance is still an issue, they may pursue rectification under Section 154 or other legal remedies, but these are separate from the Section 143(3) order. The Revenue submits that the CIT (A)'s decision

Usha Bhardwaj (Legal Representative of Ravinder Nath Bhardwaj), Noida vs. Income Tax Officer, Ward 5(3)(1), Gautam Budh Nagar, Noida

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

ITA 4567/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.4567/Del./2024, A.Y. 2012-13 Usha Bhardwaj Income Tax Officer, (Legal Representative Of Ward 5(3)(1), Ravinder Nath Bhardwaj) Vs. Income Tax Office, C-117, Sector 72, Noida, Gautam Budh Nagar, Up Gautam Budh Nagar, Up Pan: Aaapb1085C (Appellant) (Respondent)

Section 144Section 148Section 154Section 250Section 54

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

Sonali Verma, Secunderabad vs. ITO., Ward-12(6), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 778/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad30 Jul 2025AY 2020-2021

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, Gआ.अपी.सं /Ita No.778/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Smt. Sonali Verma Vs. Income Tax Officer Secunderabad Ward 12 (6) Pan:Amnpv3410A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sk Chaturvedi, Ca राज" व "ारा/Revenue By:: Shri Gurpreet Singh Sr.Ar सुनवाई की तारीख/Date Of Hearing: 23/07/2025 घोषणा की तारीख/Pronouncement: 30/07/2025 आदेश/Order

For Appellant: Shri SK Chaturvedi, CAFor Respondent: : Shri Gurpreet Singh Sr.AR
Section 139(1)Section 139(5)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 could be resorted by the assessee. Similar view has been taken in 42 Hertz Software India (P.) Ltd. v. Asstt

Mahesh Khandelwal, Indore vs. Addl JCIT (A) -1 Jaipur, Jaipur

Appeal is allowed

ITA 330/JPR/2024[2010-11]Status: DisposedITAT Indore28 Jul 2025AY 2010-11

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 139(1)Section 139(7)Section 143(1)

where the Tax Payable exceeds Rs. 100. 44)If you are not satisfied with the intimation under section 143(1) , you may seek rectification under section 154 by filing an application electronically for rectification to CPC, for which the details are available on website https://ineometax.gov.in/. '5)To know

Shetkari Shikshan Prasarak Mandal, Beed vs. DCIT(E0 Circle, Aurangabad

In the result, the appeal filed by the assessee in ITA

ITA 2176/PUN/2024[2017-18]Status: DisposedITAT Pune21 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2176/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Shetkari Shikshan Prasarak Vs. Dcit, Exemption Circle, Mandal, Aurangabad. 0 Anand Bhavan, Nagar Road, At Post Tq Ashti, Dist. Beed- 414203. Pan : Aaets0130K Appellant Respondent

For Appellant: Shri Prateek JhaFor Respondent: S/Shri Ajay Kumar Keshari &
Section 115Section 12ASection 143(1)Section 143(2)Section 143(3)Section 154Section 234ASection 250(6)Section 80G

itself. This shows that the assessee has already fulfilled his obligation under Vivad se Vishwas scheme 2020 well before initiation of proceedings of rectification under section 154 of the Income-tax Act. Learned AR further pointed out that the notice under section 154 for rectification was issued on 14th October ... also issued by the designated authority on 15th November 2021. However we also find that on 14 October 2021 a notice for rectification under section 154 was issued by the assessing officer to rectify the demand raised in the original assessment order and later rectification order under section 154

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)

receipts towards software licences. In view of the said judgment of the Hon'ble Supreme Court the assessee made an application for rectification under section 154 of the Act on the ground that as per the above judgment the benefit of tax treaty is available to the assessee and that ... offered the receipts to tax. The return was processed under section 143(1) of the Act. The assessee subsequently filed a petition for rectification under section 154 of the Act, stating that there is a mistake apparent on record in offering the impugned receipts to tax, since the receipt

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)

receipts towards software licences. In view of the said judgment of the Hon'ble Supreme Court the assessee made an application for rectification under section 154 of the Act on the ground that as per the above judgment the benefit of tax treaty is available to the assessee and that ... offered the receipts to tax. The return was processed under section 143(1) of the Act. The assessee subsequently filed a petition for rectification under section 154 of the Act, stating that there is a mistake apparent on record in offering the impugned receipts to tax, since the receipt

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)

receipts towards software licences. In view of the said judgment of the Hon'ble Supreme Court the assessee made an application for rectification under section 154 of the Act on the ground that as per the above judgment the benefit of tax treaty is available to the assessee and that ... offered the receipts to tax. The return was processed under section 143(1) of the Act. The assessee subsequently filed a petition for rectification under section 154 of the Act, stating that there is a mistake apparent on record in offering the impugned receipts to tax, since the receipt

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)

receipts towards software licences. In view of the said judgment of the Hon'ble Supreme Court the assessee made an application for rectification under section 154 of the Act on the ground that as per the above judgment the benefit of tax treaty is available to the assessee and that ... offered the receipts to tax. The return was processed under section 143(1) of the Act. The assessee subsequently filed a petition for rectification under section 154 of the Act, stating that there is a mistake apparent on record in offering the impugned receipts to tax, since the receipt

Neelkanth Niranjan Premises Co-Op Society Ltd, Mumbai vs. Income Tax Officer 23(2)(6), Mumbai

In the result, grounds of appeal of assessee are allowed

ITA 2207/MUM/2025[2020-21]Status: DisposedITAT Mumbai14 Jul 2025AY 2020-21

Bench: Shri Pawan Singh(Physical Hearing) Neelkanthniranjan Premises Co-Op Ito, Ward-23(2)(6), Mumbai Society Ltd. Vs Piramal Chambers, Lalbaug, Ground Floor, Niranjan Building, 99, Mumbai – 400012. Marine Drive, Mumbai-400002. [Pan No. Aaatn2383B] Appellant / Assessee Respondent / Revenue

Section 154Section 234ASection 254(1)Section 271(1)(c)Section 80PSection 80P(2)(d)

deduction under section 80P(2)(d). The CPC while processing the return of income not allowed such deduction. The assessee filed application for rectification under section 154. The application under section 154 was rejected by CPC and communicated to the assessee there is no mistake apparent

Bakeri Projects Private Limited, Ahmedabad vs. DCIT Circle 1(1)(1), Ahmedabad

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

ITA 954/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2020-21

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2020-21 Bakeri Projects Pvt. Lt. The Dcit, Cir.(1)(1) 1St Floor, Sanskrut Vs. Ahmedabad. Old High Court Road Off: Ashram Road Ahmedabad. Pan : Aagcb 1864 L (Applicant) (Responent)

For Appellant: Shri Deepak Shah, AR, and Shri Bharat Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR
Section 142(1)Section 143(3)Section 263Section 80I

No.954 /Ahd/2025 assessee objected to this proposal vide reply dated 17.12.2024, contending that the issue was already being agitated before the Tribunal and rectification under section 154 cannot be resorted to on debatable and controversial issues. The fact that the AO himself considered this matter under the rectification jurisdiction

Praveen Saxena, Lucknow vs. ITO-6(1), Lucknow-New

The appeal of the assessee stands allowed

ITA 202/LKW/2024[2020-21]Status: DisposedITAT Lucknow03 Jul 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 Praveen Saxena V. Income Tax Officer 6(1) Flat No.G-01, Tower-J Lucknow - New Shalimar Gallant Vigyanpuri, Mahanagar Lucknow Tan/Pan:Ajpps5818N (Appellant) (Respondent) Appellant By: Shri Samrat Chandra, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 07.02.2024, Passed By The Ld. Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 09.01.2021, Declaring A Total Income Of Rs.22,57,120/- & Also Claimed Relief Under Section 90 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) For A Sum Of Rs.3,48,632/- Being Foreign Tax Credit. The Centralized Processing Centre (Cpc) Processed The Return Under Section 143(1) Of The Act & Rejected The Relief Of Rs.3,48,632/- Claimed By The Assessee Under Section 90 Of The

For Appellant: Shri Samrat Chandra, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 139(1)Section 143(1)Section 154Section 90

assessee should have filed appeal against intimation issued under section 143(1)(a) of the Act and not against the order denying rectification under section 154 of the Act, as there was no mistake apparent from the record. The Ld. Sr. D.R. argued that the assessee was trying to make

Pratibha Jain, Indore vs. Deputy Director of Income Tax, CPC, Bengaluru

Appeal is dismissed in /imine

ITA 921/IND/2024[2023-24]Status: DisposedITAT Indore30 Jun 2025AY 2023-24

Bench: Shri B.M. Biyani

Section 139(1)Section 143(1)Section 143(3)Section 154Section 80Section 8B

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

Nanda Kishore Ravula, Hyderabad vs. ADIT (International Tax)-2, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 552/HYD/2025[2020-21]Status: DisposedITAT Hyderabad30 Jun 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.552/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2020-21) Nanda Kishore Ravula Vs. Adit (International Hyderabad Tax)-2 [Pan :Agupr0664F] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Nikhill Tiwari, Ar रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Dr सुिवधई की तधरीख/Date Of Hearing: 26/06/2025 घोर्णध की तधरीख/Date Of 30/06/2025 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.01.2025 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2020-21. 2. The Brief Facts Of The Case Are That The Assessee, An Individual, Filed His Original Return Of Income For The A.Y.2020- 21 On 15.12.2020, Declaring Total Income Of Rs.1,08,11,550/-. Subsequently, The Assessee Filed Revised Return Of Income On 30.03.2021 & Claimed Foreign Tax Credit (“Ftc”) Of 2 Nanda Kishore Ravula

For Appellant: Shri Nikhill Tiwari, ARFor Respondent: Shri Gurpreet Singh, DR
Section 139(1)Section 139(5)Section 143(1)Section 143(3)Section 154Section 91

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 (P.) Ltd. v. Asstt

Late Dev Kumar Gopaldas Aggarwal (Through Legal Reprsentative-Mr. Yogesh Devkumar Aggarwal), Mumbai vs. Income Tax Officer Ward 20(1)(1), Mumbai

In the result, the appeal of assesseeis allowed

ITA 2861/MUM/2025[2861]Status: DisposedITAT Mumbai25 Jun 2025

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Late Devkumargopaldas Aggarwal Ito, Ward-20(1)(1) 2Nd Floor, Gupta Mills Estate, Darukhana, Vs Mumbai Reay Road, Mumbai-400010. [Pan No. Aabpa0675J] Appellant / Assessee Respondent / Revenue

Section 112Section 154Section 254(1)

however, the CPC considered its exact double figure i.e. Rs. 71,39,912/-. The assessee filed application for rectification under section 154, which was rejected in a mechanical manner. The appeal of the assessee was also dismissed by ld. CIT(A) by holding that there is no mistake apparent from

Ashirwad Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exemptions) Circle, Pune

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

ITA 190/PUN/2024[2015-16]Status: DisposedITAT Pune20 Jun 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Raja B. SinghFor Respondent: Shri Ramnath P. Murkunde
Section 11Section 11(1)(a)Section 11(1)(d)Section 11(2)Section 12ASection 143(3)Section 147Section 154Section 2(15)

opinion on matters already considered in the Order of Assessment under Section 143(3) as well as in the subsequent Order of Rectification under Section 154: (b) without disposing the objection specifically raised during the reassessment proceeding; and (c) without affording the appellant an opportunity of being heard