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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

M/S Punjab Chemicals & Crop. Protection Ltd., Chandigarh vs. Addl. CIT, Neac Delhi

The appeal stand partly allowed

ITA 128/CHANDI/2021[2009-10]Status: DisposedITAT Chandigarh22 May 2025AY 2009-10

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.127/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2008-09) & 2. आयकरअपीलसं./ Ita No.128/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2009-10) M/S Punjab Chemicals & Crop. Addl. Cit Protection Ltd. Nfac बनाम/ Milestone-18, Ambala-Kalka Road Delhi Vs. Vpo Bhankharpur, Derabassi Distt. Sas Nagar (Mohali), Punjab 140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anil Khanna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2008-09 & 2009-10 Is In Second Round Of Litigation Since The Appeal Was Disposed-Off By Tribunal Vide Ita Nos.60/Chd/2013 & Ita No.100/Chd/2013 Common Order Dated 23-07-2018 For Ays 2008-09 & 2009-10 Wherein Few Of The Issues Were Restored Back To Lower

For Appellant: Shri Anil Khanna (CA) – Ld. ARFor Respondent: Ms. Kusum Bansal (CIT) – Ld. DR
Section 14ASection 154Section 36(1)(iii)

order was passed by Ld. AO on 27-03-2021 which is in further appeal before us. In the meanwhile, the assessee preferred rectification u/s 154 before Ld. DRP which was disposed-off on 17-02-2023. The rectified directions were carried out by Ld. AO vide order dated

M/S Punjab Chemicals & Crop. Protection Ltd., Chandigarh vs. Addl. CIT, Neac Delhi

The appeal stand partly allowed

ITA 127/CHANDI/2021[2008-09]Status: DisposedITAT Chandigarh22 May 2025AY 2008-09

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.127/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2008-09) & 2. आयकरअपीलसं./ Ita No.128/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2009-10) M/S Punjab Chemicals & Crop. Addl. Cit Protection Ltd. Nfac बनाम/ Milestone-18, Ambala-Kalka Road Delhi Vs. Vpo Bhankharpur, Derabassi Distt. Sas Nagar (Mohali), Punjab 140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anil Khanna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2008-09 & 2009-10 Is In Second Round Of Litigation Since The Appeal Was Disposed-Off By Tribunal Vide Ita Nos.60/Chd/2013 & Ita No.100/Chd/2013 Common Order Dated 23-07-2018 For Ays 2008-09 & 2009-10 Wherein Few Of The Issues Were Restored Back To Lower

For Appellant: Shri Anil Khanna (CA) – Ld. ARFor Respondent: Ms. Kusum Bansal (CIT) – Ld. DR
Section 14ASection 154Section 36(1)(iii)

order was passed by Ld. AO on 27-03-2021 which is in further appeal before us. In the meanwhile, the assessee preferred rectification u/s 154 before Ld. DRP which was disposed-off on 17-02-2023. The rectified directions were carried out by Ld. AO vide order dated

Eveline International, Ludhiana vs. Deputy Commissioner of Income Tax, Circle-4, Ludhiana

The appeal stand allowed for statistical purposes

ITA 942/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh16 May 2025AY 2021-22

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.942/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) M/S Everline International Dcit Circle-4 G.T.Road Aaykar Bhawan बनाम/ Vs. Ludhiana-141014 Rishi Nagar Ludhiana-141001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaafe-3412-C (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Ashwani Kumar (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 14-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 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 Learned Addl. / Joint Commissioner Of Income Tax (Appeals), Jaipur [Cit(A)] Dated 09-07-2024 In The Matter Of An Intimation Issued By Cpc U/S 143(1) On 30-09-2022 Adding Back Profit On Foreign Exchange Rate For Rs.8.87 Lacs As Reported By Tax Auditor In The Tax Audit Report. The Ld. Cit(A) Did Not Admit The Appeal For Want Of Condonation Of Delay Of 48 Days. The Ld. Ar Stated That The Adjustment Has Happened Due To Incorrect Reporting In Tax Audit

For Appellant: Sh. Ashwani Kumar (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 154

since been revised by the Tax Auditor on 28-10- 2022. 2. We are of the view that the assessee had preferred rectification u/s 154 which resulted into delayed filing of first appeal. The delay was only for 48 days which could have been condoned. Nevertheless, we direct

Kuldeep Singh, Ludhiana vs. ITO Ward (3) (1), Ludhiana

In the result, the appeal stand dismissed

ITA 717/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh16 May 2025AY 2018-19

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 717/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Shri Kuldeep Singh Ito Ward No (3)(1) बनाम/ 33F Jmd Mall Opp. Railway Station Aayakar Bhawan Vs. Punjab 141001 Rishi Nagar, Punjab. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bchps-1635-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : None ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 24-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 22-04-2024 In The Matter Of An Rectification Intimation Issued By Cpc U/S 154 Of The Act On 21-06-2023. At The Time Of Hearing, None Appeared For Assessee. Left With No Option, The Appeal Was Heard With The Able Assistance Of Ld. Sr. Dr Who Stated That The Issue Stood Squarely Covered Against The Assessee By The Decision Of Hon’Ble Apex Court.

For Appellant: NoneFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 154Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

u/s 143(1). The disallowance was in terms of Sec.43B r.w.s. 36(1)(va) as well as Sec.2(24)(x). The assessee preferred rectification u/s 154 wherein this disallowance was repeated. The Ld. CIT(A) confirmed the same, inter-alia, by relying upon the decision of Hon’ble Apex Court

Sri Poddar Madal Bhavani Samity, Kolkata vs. ITO, Ward 1(3), Exemption, Kolkata

The appeal of the assessee is dismissed

ITA 325/KOL/2025[2020-21]Status: DisposedITAT Kolkata14 May 2025AY 2020-21

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.325/Kol/2025 Assessment Year: 2020-21 Sri Poddar Madal Bhavani Samity……………………………..….……….Appellant Ground Floor, Mission Court, 25, R. N. Mukherjee Street, Kol-1. [Pan: Aabts8573R] Vs. Ito, Ward-1(3), Exemption, Kolkata.....................……........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal, Ar, Appeared On Behalf Of The Assessee. Shri Kallol Mistry, Jcit, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 13, 2025 Date Of Pronouncing The Order : May 14, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 19.12.2024 Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-2 Guwahati [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is A Public Charitable Trust Registered U/S 12A Of The Act. The Assessee Filed Its Return Of Income On 31.05.2021 By Declaring Nil Taxable Income After Claiming Application Of Income For Charitable Purposes & Accumulation U/S 11(2) Of The Act. The Cpc, Bengaluru Issued An Intimation U/S 143(1) Of The Act Dated 30.11.2021 By Disallowing The Assessee’S Claim Of Application Of Income Of Rs.13,10,039/- & Accumulation U/S 11 Of The Act At Rs.1,54,072/-. Consequently, The Entire Amount Was Treated As

Section 11Section 11(2)Section 12ASection 143(1)Section 154Section 250Section 44A

assessee has submitted that against the intimation dated 30.11.2011 u/s 143(1) of the Act, the assessee had filed an application for rectification u/s 154 of the Act before the CPC on 29.07.2022 u/s 154 of the Act, however, no relief was granted to the assessee. Subsequently, another rectification application