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“rectification u/s 154”

Rectification & RevisionSection 154Section 154426 judgments

The decision most relied on for rectification u/s 154 is Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale (1 SCR 890), cited in 18 judgments on BharatTax.

Leading authorities on rectification u/s 154

Satyanarayan Laxminarayan Hegde v. MallikarjunBhavanappa Tirumale
1 SCR 890 · 1960 · Reported
18
citing judgments

An error is not considered 'apparent from the record' for rectification purposes if it requires a lengthy process of reasoning or involves debatable points where multiple opinions are possible. A decision on a debatable point of law does not constitute a mistake apparent from the record.

Judgments citing rectification u/s 154

Jyoti Chauhan, New Delhi vs. Assessing Officer Ward 6(1), Delhi

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

ITA 6368/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Jan 2026AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Gautam Swaroop, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 10(38)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 154Section 250Section 68

quasi-judicial function vested in the appellate authority. 22. That the order passed under section 250 within a short span after rectification u/s 154 indicates pre-determination and lack of fair consideration, vitiating the appellate process. ” 3. Brief facts of the case are that the assessee filed return

Vaibhav Mittal, Jaipur vs. DCIT/ACIT 4(1), Ind, Indore

Appeal is dismissed

ITA 582/IND/2025[2012-13]Status: DisposedITAT Indore21 Jan 2026AY 2012-13

Bench: Shri Siddhartha Nautiyal

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 154Section 69A

Supreme Court in case of 7.S. Balaram, Income-tax officer Vs. Volkart Bros. 82 ITR 50 (SC) has considered the scope of rectification u/s 154 as under: "From what has been said above, it is clear that the question whether S. 17(1) of the Indian Income ... assessee has failed to demonstrate as to how the impugned addition constitutes a mistake apparent from record capable of rectification u/s 154? Even if the assessee was aggrieved by the addition made by AO u/s 69A in assessment-order, the proper legal course would have been to file an appeal

Hasbro Sa, Switzerland vs. Deputy Commissioner of Income Tax (International Tax), Circle 1(1)(1), Delhi, New Delhi

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

ITA 2842/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Ramit Kochar & Shri Raj Kumar Chauhan

Section 139(4)Section 143(1)Section 154Section 199Section 250

raised for A.Y. 2020-21. 2 Hasbro SA, Switzerland 3. Aggrieved by the said intimation, the appellant had filed an application for rectification u/s 154 of the Act before the AO. The said application was dismissed and credit of TDS amount of Rs. 21,14,675/- has not been granted

Hotel Sai Siddhi Pvt. Ltd., Nashik vs. Principal Commissioner of Income-Tax-1, Nashik

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

ITA 687/PUN/2021[2014-15]Status: DisposedITAT Pune16 Jan 2026AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 M/S. Hotel Sai Siddhi Pvt. Ltd. Pcit-1, Nashik 3/4, Poush Sector, Lekha Nagar, Vs. Mumbai Agra Road, Nashik – 422009 Pan: Aabch4310G (Appellant) (Respondent) Assessee By : Shri Sanket Joshi Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 08-01-2026 Date Of Pronouncement : 16-01-2026 O R D E R

For Appellant: Shri Sanket JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 147Section 148Section 263

detriment of the Revenue, he has ample power to either reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under

Hero Fincorp Limited, New Delhi vs. ACIT, Circle 11(1), Delhi, C.R. Building

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”, DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESDIENT (THIRD MEMBER), SHRI SATBEER

Punyashila Automobiles, Hoshangabad vs. ITO2, Itarsi

Appeal is allowed for statistical purpose

ITA 476/IND/2025[2016-17]Status: DisposedITAT Indore08 Jan 2026AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyani**

Section 143(1)Section 250Section 40

again occurred due to which the AO made similar disallowance in the intimation u/s 143(1) but, subsequently, the AO has made rectification u/s 154 and deleted disallowance. To show this, Ld. AR filed copies of intimation u/s 143(1) and rectification-order u/s 154 passed

Parantap Charitable Trust, Vadodara vs. The ITO, Ward- Exemption, Vadodara

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

ITA 1697/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2017-18

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1697/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2017-18) बनाम Parantap Charitable Trust Income Tax Officer 421, Vraj Siddhi Tower, Ward – Exemption, / Khanderao Market Char Vadodara Vs. Rasta, Rajmahal Road, Vadodara - 390001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aactp0976E (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Rushin Patel, Ar ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr 07/01/2026 Date Of Hearing Date Of Pronouncement 08/01/2026 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Hereinafter Referred To As “Nfac”), Delhi (Hereinafter Referred To As “Cit(A)”) Dated 15.06.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As The “Act”) & Relates To Assessment Year (A.Y.) 2017-18. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

For Appellant: Shri Rushin Patel, ARFor Respondent: Smt. Mamta Singh, Sr. DR
Section 11Section 139Section 139(4)Section 143(1)Section 154Section 250

rectification request u/s 154. hereafter ITA No.1697/Ahd/2025 [Parantap Charitable Trust vs. ITO] A.Y. 2017-18 - 3 – 07.06.2019 CPC rejected rectification u/s 154. Appeal Papers 17.07.2019 Assessee filed appeal before ld. CIT(A) Form 35 against the rectification order dated 07.06.2019. 24.07.2019 Assessee also filed rectification request u/s Pg-9 154 ... hereafter 03.09.2025 Assessee filed appeal before the Hon'ble Appeal ITAT. Papers 3. Since the exemption u/s 11 was granted by way of rectification u/s 154 on 06.08.2019 and since the Id. CIT(A) has also held furnishing of Form 10B as procedural requirement which can be complied even during

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)

facts and circumstances of the case, the Ld CIT Appeal has erred in law and fact in confirming and rejecting the application for rectification u/s 154 of the Act to allow the deduction of Rs.2,65,526/- u/s 80P of the Act even though it is a mistake apparent from

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)

facts and circumstances of the case, the Ld CIT Appeal has erred in law and fact in confirming and rejecting the application for rectification u/s 154 of the Act to allow the deduction of Rs.2,65,526/- u/s 80P of the Act even though it is a mistake apparent from

Devang Yogesh Metha, Mumbai vs. ITO Ward-19(1)(5), Mumbai

ITA 5211/MUM/2025[2021-22]Status: DisposedITAT Mumbai29 Dec 2025AY 2021-22

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri. Vijay Mehta, ARFor Respondent: Assessee by
Section 139Section 139(4)Section 139(9)Section 140BSection 143(1)Section 143(1)(a)Section 154Section 2Section 250Section 44A

carried before Ld. CIT(A), but the appeal of assessee has been dismissed in limine, stating that the assessee had already applied for rectification u/s 154 before filing the appeal against the intimation u/s 143(1) dated 30/12/2023, thus, can file an appeal directly against the order u/s 154 ... assessee on 29.03.2023, as a remedial action on rejection of the first return dated 24.12.2022 along with protesting the rejection through rectification u/s 154 as well as by appeal before the First Appellate Authority, should be ignored. Once the assessee’s first return is held as valid return

Pitamber Wadhwani, Indore vs. DCIT-1(1), Indore

Appeal is allowed for statistical purpose

ITA 513/IND/2025[2017-18]Status: DisposedITAT Indore23 Dec 2025AY 2017-18

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniassessment Year:2017-18 Pitamber Wadhwani, Dcit-1(1) 101, Saakaar Kunj, 3 Indore बनाम/ Shanti Nagar, Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aacpw6714B Assessee By Shri Sandeep Garg, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 23.12.2025

Section 143(3)Section 154Section 249Section 250Section 253(5)

made a factual and cogent submission to Ld. CIT(A) that against assessment-order passed by AO, the assessee filed an application for rectification u/s 154 to the very same AO but ultimately finding no outcome from AO, the assessee filed first-appeal to CIT(A) after lapse of time ... submissions of Ld. AR. 3.3 After a careful consideration, we are of the view that when the assessee was pursuing alternate remedy of rectification u/s 154 against assessment-order, there was no willful attempt of assessee to avoid the filing Page 5 of 7 Pitamber Wadhwani ITA No. 513/Ind/2025

Federal Mogul Holdings, Ltd, Mauritius vs. ACIT Circle Intl Tax 1(3)(1), New Delhi

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

ITA 4180/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(1)Section 154

show caused as to how the rectification request qualifies as a mistake apparent from record and as to why request of assessee for rectification u/s 154 of the Act, should not be rejected. The AO further noted that in response to the show cause notice dated 07.06.2024, the assessee submitted ... show caused as to how the rectification request qualifies as a mistake apparent from record and as to why request of assessee for rectification u/s 154 of the Act, should not be rejected. 6. In response to the show cause notice dated 07.06.2024, assessee submitted its response vide letter dated

Kedambadi Milk Producers Co-Operative Women Society Limited, Kedambadi vs. Income Tax Officer Ward 1 Puttur, Puttur

In the result appeal of the assessee is dismissed

ITA 280/BANG/2025[2019-2020]Status: DisposedITAT Bangalore22 Dec 2025AY 2019-2020

Bench: Shri Prashant Maharishiassessment Year : 2019-20

For Appellant: Shri Krishna Kantila, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 139Section 139(1)Section 143Section 154Section 80Section 80ASection 80PSection 80p

communication for adjustment on 3/8/2020 and then intimation was passed. Assessee filed rectified return u/s 154 of the act , The intimation rejecting such rectification u/s 154 was passed on 27 June 2023 wherein the above deduction was also once again denied by holding that that there is an incorrect claim ... within due date, assessee is not eligible for deduction and adjustment made in original adjustments u/s 143 91) is proper. Accordingly request for rectification u/s 154 is rejected , assessee was denied above deduction. 5. Aggrieved with the same assessee preferred an appeal before the learned CIT – A. The learned

Chikkamudnoor Milk Producers Co-Operative Society Limited, Chikkamudnoor vs. Income Tax Officer, Ward-1, Puttur

In the result appeal of the assessee is dismissed

ITA 104/BANG/2025[2019-20]Status: DisposedITAT Bangalore22 Dec 2025AY 2019-20

Bench: Shri Prashant Maharishiassessment Year : 2019-20

For Appellant: Shri Krishna Kantila, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 139Section 139(1)Section 143Section 154Section 80Section 80ASection 80PSection 80p

communication for adjustment on 3/8/2020 and then intimation was passed. Assessee filed rectified return u/s 154 of the act , The intimation rejecting such rectification u/s 154 was passed on 27 June 2023 wherein the above deduction was also once again denied by holding that that there is an incorrect claim ... within due date, assessee is not eligible for deduction and adjustment made in original adjustments u/s 143 91) is proper. Accordingly request for rectification u/s 154 is rejected , assessee was denied above deduction. 5. Aggrieved with the same assessee preferred an appeal before the learned CIT – A. The learned

Prakashchand, Chennai vs. ITO, TDS Ward-1, Chennai

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

ITA 3065/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Dec 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Hitesh, AdvocateFor Respondent: 17.12.2025
Section 154Section 200A(1)(c)Section 234ESection 3

without r passed u/s 154 of the Act is without r passed u/s 154 of the Act is without jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154

Prakashchand, Chennai vs. ITO, TDS Ward 1, Chennai

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

ITA 3064/CHNY/2025[2013-14]Status: DisposedITAT Chennai18 Dec 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Hitesh, AdvocateFor Respondent: 17.12.2025
Section 154Section 200A(1)(c)Section 234ESection 3

without r passed u/s 154 of the Act is without r passed u/s 154 of the Act is without jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154

Prakashchand, Chennai vs. ITO, TDS Ward-1, Chennai

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

ITA 3063/CHNY/2025[2013-14]Status: DisposedITAT Chennai18 Dec 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Hitesh, AdvocateFor Respondent: 17.12.2025
Section 154Section 200A(1)(c)Section 234ESection 3

without r passed u/s 154 of the Act is without r passed u/s 154 of the Act is without jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154

Prakashchand, Chennai vs. ITO, TDS Ward-1, Chennai

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

ITA 3061/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Dec 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Hitesh, AdvocateFor Respondent: 17.12.2025
Section 154Section 200A(1)(c)Section 234ESection 3

without r passed u/s 154 of the Act is without r passed u/s 154 of the Act is without jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154 of the Act cannot exist jurisdiction, since a rectification u/s 154

Sh. Dhan Singh Meena, Dy. Commissioner of Income Tax, Central Circle, Kota vs. Srishti Associates, Kota

13. In view of the above discussion, reasons and findings, present appeal filed by the department deserves to be dismissed

ITA 1189/JPR/2025[2018-19]Status: HeardITAT Jaipur17 Dec 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 115BSection 131Section 132(1)Section 132(4)Section 139Section 143(2)Section 143(3)Section 153CSection 154Section 250

above said notice dated 15.02.2023. Ultimately, rectification order dated 28.02.2023 was passed while observing that the mistake was apparent from record calling for rectification u/s 154 of the Act, as regards applicability of the provisions of section 115BBE of the Act, as regards the above said undisclosed income

Sanket Kailas Pawar, Pune vs. ITO, Ward-1(5), Aurangabad

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

ITA 232/PUN/2025[2019-20]Status: DisposedITAT Pune09 Dec 2025AY 2019-20

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1194/Pun/2024 िनधा"रण वष" / Assessment Year : 2019-20 Sanket Kailas Pawar, Vs. Ito, Ward-1(5), Plot No.20, Sattyam Nagar, Aurangabad. Cidco No.7, Jalgaon Road, Aurangabad- 431010. Pan : Bugpp3328D Appellant Respondent आयकर अपील सं. / Ita No.232/Pun/2025 िनधा"रण वष" / Assessment Year : 2019-20 Sanket Kailas Pawar, Vs. Ito, Ward-1(5), Rl-191, Krushnakunj Aurangabad. Banglow, G Block, Sambhaji Nagar, Chinchwad, Pune- 411019. Pan : Bugpp3328D Appellant Respondent Assessee By : Shri Prateek Jha & Shri Prayag Jha Revenue By : Shri Amit Bobde Date Of Hearing : 28.10.2025 Date Of Pronouncement : 09.12.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 & 07.12.2024 Passed By Ld. Addl./Jcit(A)-2, Noida [‘Ld. Cit(A)’] For The Assessment Year 2019-20 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, 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.232/Pun/2025 For Adjudication As The Lead Case.

For Appellant: Shri Prateek Jha &For Respondent: Shri Amit Bobde
Section 10(37)Section 143(1)Section 154

claim for exempt income u/s 10(37) of the IT Act amounting to Rs.6,06,67,714/-. In response to application for rectification u/s 154 of the IT Act, the Assessing Officer vide order dated 24.01.2022 rejected the rectification application filed by the assessee u/s 154