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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

Judgments citing rectification u/s 154

Sarnath Co-Op Housing Society Ltd, Mumbai vs. CIT(A), Mumbai

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

ITA 2550/MUM/2025[2020-21]Status: DisposedITAT Mumbai16 Jul 2025AY 2020-21

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhan1. Ita No. 2548/Mum/2025 (A.Y: 2013-14) 2. Ita No. 2549/Mum/2025 (A.Y: 2015-16) 3. Ita No. 2550/Mum/2025 (A.Y: 2020-21) Sarnath Co-Operative Housing Society Ltd. 59-B, Sarnath Co-Operative Housing Society Ltd, Bhulabhai Desai Road, Breach Candy, Mumbai-400 026 Pan: Aaaas3230K Ito Ward 15(1)(4), Vs. Mumbai. (Appellant) Assessee Represented By Department Represented By Date Of Conclusion Of Hearing Date Of Pronouncement : : : : (Respondent) Shri Pawan Choudhary, Ld. Ar Shri Pravin Salunkhe (Sr. Dr.) 02.07.2025 16.07.2025 Order Per Raj Kumar Chauhan (J.M.): 1. These Appeals Are Filed By The Appellant/Assessee Against The Separate Orders Dated 27.02.2025 Of Learned Commissioner Of Income Tax (Appeals)/Addl/Jcit (A)-4, Hyderabad [Hereinafter Referred To As The “Cit(A)"], Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act"] For The A.Y. 2013-14, 2015-16 & 2020-21 Respectively, Wherein The Appeals Of The Assessee Are Dismissed Being Barred By Limitation & The Ld. Cit(A) Has Refused To Condone The Delay Stating That The Assessee Has Failed To Show Sufficient Cause For Condonation Of Delay. 2. Since The Facts Of All The Appeals Filed By The Assessee Are Exactly Same, Parties Are Same, Also The Order Of The Same Date & The Matter Involved Is Also Similar Wherein The Assessee Has Challenged The Disallowance Of Interest Amount Earned From Deposit Of Interest With The Cooperative Banks & Was Claimed As Deduction U/S 80P(2)(D) Of The Act For The Different

Section 143(1)Section 250Section 80PSection 80P(2)(d)

management and staff. Although the return was processed and an intimation under section 143(1) of the Income Tax Act was received, The rectification u/s 154 was filed for 3 Assessment years out of Appeal filed for 4 Assessment year, since an application against 143(1) order was pending

Sarnath Co-Op Housing Society Ltd, Bhulabhai Desai vs. CIT(Appeal), Piramal Chamber

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

ITA 2548/MUM/2025[2013-14]Status: DisposedITAT Mumbai16 Jul 2025AY 2013-14

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhan1. Ita No. 2548/Mum/2025 (A.Y: 2013-14) 2. Ita No. 2549/Mum/2025 (A.Y: 2015-16) 3. Ita No. 2550/Mum/2025 (A.Y: 2020-21) Sarnath Co-Operative Housing Society Ltd. 59-B, Sarnath Co-Operative Housing Society Ltd, Bhulabhai Desai Road, Breach Candy, Mumbai-400 026 Pan: Aaaas3230K Ito Ward 15(1)(4), Vs. Mumbai. (Appellant) Assessee Represented By Department Represented By Date Of Conclusion Of Hearing Date Of Pronouncement (Respondent) Shri Pawan Choudhary, Ld. Ar Shri Pravin Salunkhe (Sr. Dr.) 02.07.2025 16.07.2025 Order Per Raj Kumar Chauhan (J.M.): 1. These Appeals Are Filed By The Appellant/Assessee Against The Separate Orders Dated 27.02.2025 Of Learned Commissioner Of Income Tax (Appeals)/Addl/Jcit (A)-4, Hyderabad [Hereinafter Referred To As The “Cit(A)"], Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act"] For The A.Y. 2013-14, 2015-16 & 2020-21 Respectively, Wherein The Appeals Of The Assessee Are Dismissed Being Barred By Limitation & The Ld. Cit(A) Has Refused To Condone The Delay Stating That The Assessee Has Failed To Show Sufficient Cause For Condonation Of Delay. 2. Since The Facts Of All The Appeals Filed By The Assessee Are Exactly Same, Parties Are Same, Also The Order Of The Same Date & The Matter Involved Is Also Similar Wherein The Assessee Has Challenged The Disallowance Of Interest Amount Earned From Deposit Of Interest With The Cooperative Banks & Was Claimed As Deduction U/S 80P(2)(D) Of The Act For The Different

Section 143(1)Section 250Section 80PSection 80P(2)(d)

management and staff. Although the return was processed and an intimation under section 143(1) of the Income Tax Act was received, The rectification u/s 154 was filed for 3 Assessment year out of Appeal filed for 4 Assessment year, since an application against 143(1) order was pending

M/S Rajasthan Knowledge Corporation Ltd., Jaipur vs. ACIT, Circle-1, Jaipur

10. In view of the above discussion and findings, this appeal is partly allowed and the impugned order passed by Learned CIT(A) is set aside whereby disallowance of bonus to the tune of Rs

ITA 279/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Jul 2025AY 2018-19

Bench: Learned Cit(A), Nfac, Delhi, While Challenging Order Dated 25.07.2022 Issued U/S 154 Of Income Tax Act, 1961 (In Short “The Act”), Came To Be Dismissed, While Observing As Under:- “5.6 In View Of The Above, Mandatory Condition Of Making The Payment Of The Employees Contribution To The Pf & Esi Funds Within 15 Days Of The Close Of Every Month, Has Not Been Fulfilled By The Appellant So As To Be Entitled For Claim Of Deduction U/S 36(1)(Va) Of The Act. Accordingly, The Ao’S Action Of Disallowing The Amount On Account Of Disallowance Of Bonus Amount Of Rs. 14,03.,538/- & 2 M/S Rajasthan Knowledge Corporation Ltd., Jaipur. Employees Contrition To Pf Of Rs. 5,172/- Is Hereby Confirmed & Grounds Of Appeal Filed By The Appellant Are Treated As Dismissed.”

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 139(1)Section 143(1)Section 154Section 36(1)(va)Section 43BSection 44A

u/s 143(1) dated 16.10.2022; 4 M/S Rajasthan Knowledge Corporation Ltd., Jaipur.  Copy of acknowledgment of return dt. 04.01.2022;  Copy of Application for Rectification u/s 154;  Copy of following documents relating to the payment of bonus before due date of filing the return:-  Kotak bank statement of assessee.  Ledger account

Kanya Gurukul Shiksha Samiti, Nilokheri vs. Income Tax Officer (Exemption), Ambala

The appeal stand dismissed as withdrawn

ITA 1/CHANDI/2025[2021-2022]Status: DisposedITAT Chandigarh02 Jun 2025AY 2021-2022

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 1/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Kanya Gurukul Shiksha Samiti Ito (Exemption) बनाम/ Anjanthali Nilokheri Aaykar Bhawan 2Nd Floor B. C. Bazaar Haryana132021 Vs. Ambala Cantt-133001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaffk-8836-M (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri S. B. Gupta (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Vivek Vardhan (Addl. Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 22-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-06-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. During Hearing Of Captioned Appeal, It Transpires That The Return Of Income As Filed By The Assessee Was Initially Processed U/S 143(1). The Assessee Filed Rectification U/S 154 Which Was Disposed-Off By Cpc On 15-12-2022. The Assessee Preferred First Appeal Against This Order Which Was Disposed-Off Vide Order Dated 09-09-2024 Wherein Ld. Ao Was Directed To Allow Certain Expenditure. In The Set-Aside Proceedings, Ld. Ao Re-Determined Income Of Rs.19.49 Lacs Vide Order Dated 06-11-2024. Against This Order, The Assessee Has Filed

For Appellant: Shri S. B. Gupta (Advocate) – Ld. ARFor Respondent: Shri Vivek Vardhan (Addl. CIT) - Ld. Sr. DR
Section 143(1)Section 154

captioned appeal, it transpires that the return of income as filed by the assessee was initially processed u/s 143(1). The assessee filed rectification u/s 154 which was disposed-off by CPC on 15-12-2022. The assessee preferred first appeal against this order which was disposed-off vide order

Sgj Enterprises Private Limited, Patiala vs. DCIT, Circle, Patiala

In the result, the appeal was dismissed against which the assessee is in further appeal before us

ITA 645/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh02 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 645/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2020-21) M/S Sgj Enterprises Private Limited Dcit-Circle Patiala बनाम/ D-197 Focal Point Aaykar Bhawan Vs. Patiala 147001 Patiala "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aancs-8860-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 22-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-06-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2020- 21 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Fearless Appeals Centre Delhi [Cit(A)] Dated 22- 12-2023 In The Matter Of Rectification Intimation Issued By Cpc U/S 154 Of The Act On 21-06-2022. The Sole Grievance Of The Assessee Is Application Of Correct Rate Of Tax. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under. The Registry Has Noted Delay Of 93 Days In The Appeal Which Stands Condoned.

For Appellant: Shri Parikshit Aggarwal (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 115BSection 143(1)Section 154

rate of 30% as applicable to companies. On the other hand, the assessee had applied concessional rate of 25%. Aggrieved, the assessee preferred rectification u/s 154 which was also rejected by CPC vide intimation dated 21-06-2022. The Ld. CIT(A) rejected the appeal on the ground that