“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

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

Kothari Agritech Private Limited, Solapur vs. DCIT Circle-1, Solapur

In the result, the both appeals of the assessee in ITA Nos

ITA 2392/PUN/2024[2018-19]Status: DisposedITAT Pune09 Sept 2025AY 2018-19

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

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Ramnath P Murkunde

Section 143Section 143(1)Section 143(1)(a)Section 143(3)Section 14ASection 154Section 80Section 801ASection 80ISection 80J

that Form 10CCB was not filed within the due date. The assessee being aggrieved by the said intimation order, filed an application for rectification u/s 154 of the Act before the Ld. Jurisdictional Assessing Officer (“JAO”). Subsequently, the case of the assessee was selected for scrutiny under CASS, amongst others ... Madras High court, also quoted by the assessee, it can be concluded that any erroneous assessment cannot be subject matter for rectification u/s 154 and in such a scenario assessee should get it rectified only under procedure known to law by carrying the matter before the appropriate authority

Family Physicians Association, Bangalore vs. Income Tax Officer, (Exemption), Ward, Bangalore

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

ITA 946/BANG/2025[2016-17]Status: DisposedITAT Bangalore09 Sept 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2016-17 Family Physicians Association, Vs. Ito (Exemptions), #202-3 Mahesh Clinic, Ward, R T Street, B V K Iyengar Road Cross, Bangalore. Bangalore – 560 053, Karnataka. Pan :Aaatf 1083 G Appellant Respondent Assessee By : Shri. Nagesh, Ca Revenue By : Shri. Ganesh R Gale, Standing Counsel For Department. Date Of Hearing : 15.07.2025 Date Of Pronouncement : 09.09.2025

For Appellant: Shri. Nagesh, CAFor Respondent: Shri. Ganesh R Gale, Standing Counsel for Department

Section 11(2)Section 143(1)Section 249(3)

copy of 143(1) only after filing of grievance letter as mentioned above. After receipt of intimation he filed Page 4 of 5 rectification u/s 154 which was rejected. Thereafter assessee filed appeal before the CIT(A). The learned CIT(A) rejected the appeal as there was inordinate belay

Anil Kumar, Bilaspur vs. Income Tax Officer, Ward Hamirpur

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

ITA 83/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh03 Sept 2025AY 2021-22

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 83/Chd/2025 "नधा"रण वष" / Assessment Year : 2021-22 Anil Kumar, Ito, बनाम Vilalge Malkot, Ward, Po Lehri, Hamirpur Vs. Sarail, Bharari, H.P. 174027 "थायी लेखा सं./Pan No: Dympk2533K अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Parveen Sharma, Advocate (Virtual) राज"व क" ओर से/ Revenue By : Sh. Vivek Varadhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 02.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 03.09.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 13.01.2025 Of Addl./Jcit(A)-7, Kolkata Fopr A.Y. 2021-22. 2. Grounds Of Appeal Are As Under: -

For Appellant: Sh. Parveen Sharma, Advocate (Virtual)For Respondent: Sh. Vivek Varadhan, Addl. CIT, Sr.DR

Section 143(1)Section 154

that the appellant filed return of income which was processed u/s 143(1) by CPC raising certain demand. The appellant prayed for rectification u/s 154 of the said Intimation but CPC passed order u/s 154 keeping the demand unchanged. The only issue involved in this case is that the appellant ... Counsel for the Assessee submitted that the Assessing Officer CPC, Bengaluru did not consider the request of the Assessee to make rectification u/s 154 of the Income Tax Act, 1961 (in short 'the Act') and upheld the assessment framed u/s 143(1) of the Act whereby the income

Suraj Co Operative Housing Society Limited, Mumbai vs. ITO Ward 19(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 2350/MUM/2025[2021-22]Status: DisposedITAT Mumbai29 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai () I.T.A. No. 2347/Mum/2025 Assessment Year: 2013-14

Section 143(1)Section 154Section 51Section 80PSection 80P(2)(d)

there was sufficient reason for delay in filling of appeal. b) The learned ADDL/JCIT (A) erred in not considering that the application for rectification u/s 154 for allowing deduction u/s 80P was pending before AO. Application was not disposed of 3 On facts and circumstances of the case

Suraj Co Operative Housing Society Limited, Mumbai vs. ITO Ward 19(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 2349/MUM/2025[2020-21]Status: DisposedITAT Mumbai29 Aug 2025AY 2020-21

Bench: Smt. Beena Pillai () I.T.A. No. 2347/Mum/2025 Assessment Year: 2013-14

Section 143(1)Section 154Section 51Section 80PSection 80P(2)(d)

Suraj Co Operative Housing Society Limited, Mumbai vs. ITO Ward 19(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 2348/MUM/2025[2019-20]Status: DisposedITAT Mumbai29 Aug 2025AY 2019-20

Bench: Smt. Beena Pillai () I.T.A. No. 2347/Mum/2025 Assessment Year: 2013-14

Section 143(1)Section 154Section 51Section 80PSection 80P(2)(d)

Suraj Co Operative Housing Society Limited, Mumbai vs. ITO Ward 19(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 2347/MUM/2025[2013-14]Status: DisposedITAT Mumbai29 Aug 2025AY 2013-14

Bench: Smt. Beena Pillai () I.T.A. No. 2347/Mum/2025 Assessment Year: 2013-14

Section 143(1)Section 154Section 51Section 80PSection 80P(2)(d)

Sh. Nanu Ram Choyal, Jaipur vs. ITO, Ward-Behror, Alwar

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

ITA 1015/JPR/2025[2011-12]Status: DisposedITAT Jaipur28 Aug 2025AY 2011-12

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 154

rectified by way of rectification of mistake u/s154 of the Act. In other words, in the garb of exercise of the power of rectification u/s 154 of the Act, the income-tax 3 SHRI NANU RAM CHOYAL VS ITO,WARD-BEHROR, ALWAR authorities cannot revise or review their order generally

Veeranan Srinivasan, K.K.Nagar, Madurai vs. Deputy Commissioner of Income Tax, Non Corporate Circle-1, Madurai, Income Tax Office

ITA 1136/CHNY/2025[2017-2018]Status: DisposedITAT Chennai26 Aug 2025AY 2017-2018

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1136/Chny/2025

Section 115BSection 132Section 143(3)Section 154Section 69B

there was any mistake in the order of the Ld.AO u/s 143(3) r.w.s.153A and secondly whether the said mistake was amenable for rectification u/s 154. As far as the first controversy is concerned it is the case of the assessee that a mistake has arisen in the order ... adoption of the impugned figure of Rs.86,67,857/-. The larger question that however comes here is whether this mistake was amenable for rectification u/s 154 or not. The request of the assessee is actually maintainable from the point of view of authority given in section 154. The assessee

Shri Sainath Sevabhavi Sanstha, Latur vs. ITO, Exemption Ward, Nanded

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

ITA 1319/PUN/2025[2013-14]Status: DisposedITAT Pune22 Aug 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1319/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Shri Sainath Sevabhavi Vs. Ito, Exemption Ward, Sanstha, Nanded. Akharwai, Harangul Bk, Latur, Harangai Bk, B.O., Latur- 413531. Pan : Aakts9324H Appellant Respondent Assessee By : Shri Sarang Gudhate Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 30.07.2025 Date Of Pronouncement : 22.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.04.2025 Passed By Ld. Addl./Jcit(A)-7, Delhi [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “(Without Prejudice To Each Other) 1. Under The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A)/Nfac Has Erred In Not Condoning The Delay In Filing Of Appeal. 2. Under The Facts & Circumstances Of The Case & In Law, Ld Cit(A)/Nfac Has Erred In Denying The Expenditure Incurred & Treating The Gross Receipts As Income In Intimation U/S 143(1).

For Appellant: Shri Sarang GudhateFor Respondent: Shri Akhilesh Srivastva

Section 119(2)(b)Section 143(1)Section 154

cause which prevented the assessee to file appeal within prescribed time limit. In this 4 regard, Ld. AR submitted that the application for rectification u/s 154 of the IT Act was allowed by ITO, Latur and was sent for approval of refund before Addl.CIT who rejected the same by saying ... incurred & claimed by the assessee. However, at the same time, we also find that the assessee filed application dated 22-12-2017 for rectification u/s 154 of the IT Act & his subsequent manual application dated 27-01-2020 u/s 154 for rectification was considered by ITO, Latur & refund of Rs.4

The Straw Board Manufacturing Company Limited, Bajwara, Hoshiarpur vs. Income Tax Officer Ward-1, Hoshiarpur

The appeal stand allowed

ITA 318/ASR/2024[2021-22]Status: DisposedITAT Amritsar21 Aug 2025AY 2021-22

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकर अपील सं./ Ita No. 318/Asr/2024 (िनधा"रण वष" / Assessment Year: 2021-22) The Straw Board Manufacturing Ito Company Ltd Ward 1 बनाम/ Vs. C/O Lala Shri Chunilal Free Hospital Hoshiarpur. Bajwara, Hoshiarpur – 146 023 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaact-5095-K (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Sh. Sandeep Vijh (Ca) –Ld.Ar ""थ"कीओरसे/Respondent By : Sh. Charan Dass (Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 04-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Ld. Addl. / Joint Commissioner Of Income Tax (Appeals), Kolkata [Cit(A)] Dated 26-03-2024 In The Matter Of An Intimation Issued By Cpc U/S. 143(1) Of The Act On 22-11-2022 Proposing Certain Adjustment Of Rs.6.58 Lacs To The Returned Income Of The Assessee. The Ld. Cit(A) Confirmed Adjustment Of Rs.5.94 Lacs Against Which The Assessee Is In Further Appeal Before Us. Having

For Appellant: Sh. Sandeep Vijh (CA) –Ld.ARFor Respondent: Sh. Charan Dass (CIT) – Ld. Sr. DR

Section 143(1)Section 143(1)(a)Section 154Section 43B

Rs.1,04,952/-. However, total income as computed by the assessee was accepted by CPC without making these adjustments. 3. Apprehending any possible rectification u/s 154, the assessee preferred first appeal against the same. It was pointed out that the figure of Rs.10,35,757/- comprised-off profit on sale ... confirmed by Ld. CIT(A) is warranted on these facts. The first appeal was filed by the assessee only on apprehension of possible rectification u/s 154. This being so, the adjustment so sustained in the impugned order, stand deleted. We order so. The appeal stand allowed. 5. Order pronounced

Elca Cosmetics Pvt Ltd, Delhi vs. DCIT, Circle-7(1), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1571/DEL/2025[2015-16]Status: DisposedITAT Delhi19 Aug 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(3)Section 154

account of provision for sales return of Rs. 6,00,12,038/-, and (ii) treating the said provision as a subject matter of rectification u/s 154 of the Act. 4. Briefly stated, the facts of the case are that the assessee filed its revised return of income for the year

Universal Trading Company Limited, Kolkata vs. DCIT, Circle 5(1), Kolkata

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

ITA 223/KOL/2025[2012-13]Status: DisposedITAT Kolkata12 Aug 2025AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115Section 115JSection 154Section 237Section 244ASection 250

provisions of section 237 of the Act relating to refund. It was submitted by the Ld. AR that in AY 2014- 15 vide rectification u/s 154 of the Act, the refund was allowed while in AY 2016-17 the Ld. CIT(A) had granted relief to the assessee

Osaka Alloys & Steel Private Limited, Jalandhar vs. DCIT/ACIT, Circle-1, Jld, Jalandhar

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

ITA 60/ASR/2025[2012-13]Status: DisposedITAT Amritsar07 Aug 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &

Section 115Section 115JSection 143(1)Section 154Section 154oSection 2(24)Section 250Section 250oSection 80I

matter is also a debatable issue and involves interpretation of law and as such it does not fall within the purview of rectification u/s 154 of the Act. 13. He further referred to the copy of the assessment order for the assessment year 2014-15 which is enclosed in page ... deduction u/s 80IB of the Act, amounting to Rs. 17.38 lakhs, which was disallowed in proceedings u/s 143(1), against which application for rectification u/s 154, was filed by the assessee and the AO allowed the said claim u/s 80IB vide order dated 30/03/2018. 11 I.T.A. No. 60/Asr/2025 Assessment Year

Bharat Jain, Sarita Vihar, New Delhi vs. AO/ADIT-CPC Bengaluru, Civic Centre, New Delhi

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

ITA 4986/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Aug 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahmanbharat Jain, Vs. Adit – Cpc, Flat No.133, Pocket G, Sfs Flats, Bengaluru. Maharaja Agarsen Marg, Sarita Vihar, New Delhi – 110 076. (Pan : Aaapj4180E) (Appellant) (Respondent) Assessee By : Shri Nitin Kanwar, Advocate Shri Shivam Jain, Advocate Shri Rajiv Kumar, Advocate Revenue By : Shri Ramesh Chand, Sr. Dr Date Of Hearing : 14.05.2024 Date Of Order : 06.08.2024 O R D E R Per S.Rifaur Rahman: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac) [“Ld. Cit(A)”, For Short] Dated 28.08.2024 For The Assessment Year 2020-21. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Brought To Our Notice Return Of Income Filed By The Assessee For The Ay 2020-21 Wherein The Status Of 2 The Assessee Was Clearly Mentioned As Non-Resident As Residential Status Of The Assessee In Itr 3 Filed On 16.12.2020 With The Acknowledgement No.826193800161220. With The Above Facts On Record, He Submitted That The Authorities Below Proceeded To Apply The Provisions Of Section 44Ada Of The Income-Tax Act, 1961 (For Short ‘The Act’) For The Reason That Assessee Has Not Maintained Proper Books Of Account For Carrying On The Professional Activities, Therefore, They Applied The Presumptive Tax @ 50%. He Submitted That Provisions Of Section 44Ada Are Not Applicable To The Non-Resident & It Was Wrongly Applied In Assessee’S Case. He Further Submitted That The Ld. Cit (A) Dismissed The Appeal By Observing As Under:-

For Appellant: Shri Nitin Kanwar, AdvocateFor Respondent: Shri Ramesh Chand, Sr. DR

Section 143(1)Section 154Section 30Section 44A

allowed and therefore the restriction imposed by the CPC while processing the return of income u/s 143(1) and the subsequent rejection for rectification u/s 154 is found to be in order and does not call for any interference. The JAO is directed to compute the taxable income accordingly

Rajvi Jewellers, Panchmahal vs. The Dy.CIT, Anand Circle, Anand

In the result, appeal of the assessee is dismissed

ITA 232/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad28 Jul 2025AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Respondent: Smt. Malarkodi R., Sr. DR

Section 133ASection 143(3)Section 154Section 69B

there was no mistake on part of CIT(Appeals) in upholding rectification of original order, which contained a mistake apparent from record, requiring rectification u/s 154 of the Act. 6. In the result, appeal of the assessee is dismissed. This Order pronounced in Open Court on 28/07/2025 Sd/- Sd/- (ANNAPURNA

Bandigadi Chandrappashetty Rajashekarappa, Shimoga vs. Income Tax Officer, Ward-1, Shimoga

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

ITA 307/BANG/2025[2015-16]Status: DisposedITAT Bangalore23 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravishankar S.V AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT (DR)

Section 143(3)Section 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