In the result, the assessee’s appeal is (in ITA No
Bench: Sh. Sanjay Arorai.T.A. Nos. 561/Asr/2018 & 284/Asr/2017 Assessment Year: 2006-07
Section 154(8) makes this further clear, i.e., that any order of amendment u/s. 154(1) r/w sec. 154(4) has to be a result of a conscious decision by the concerned authority to either amend or not to amend the order sought to be rectified. The time frame stipulated thereby is, even as clarified in SBI v. ITO (TDS