“rectification u/s 154”

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

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

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.

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

Varunendra Narayan Deekshit, Pune vs. CIT(A), Pune

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

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

above section 154(3) of the Act, we are of the considered opinion that the notice is a must before making any rectification u/s 154 of the Act and in the instant case in hand admittedly the CPC has not issued any notice to the assessee prior to making

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

mistake appearance from the record. In this regard, it is well settled law that a debatable point cannot be a reason for rectification u/s 154. Further, in order to invoke section 154 for rectification of the mistake, the mistake sought to be rectified should be a mistake apparent

Ramesh Shankarrao Wagh, Pune vs. Assessing Officer Ward 8(3), Pune

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

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

filing the return of income u/s 139(1) of the Act. On receipt of above intimation, the assessee filed Form 3CFA & applied for rectification u/s 154 of the Act before CPC. Vide order dated 22.03.2023 CPC issued another intimation however desired relief was not given to the assessee. 4. Being