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2023 (8) TMI 821 - AT - Income TaxRectification u/s 154 - Period of limitation - Late fee u/s. 234E - delay in filing quarterly E-TDS return - HELD THAT:- We find that the observation of the CIT(Appeals), NFAC that as per the provisions of Section 154 rectification of a mistake can be made only upto four years from the end of the financial year in which the order sought to be rectified was passed, has not been assailed by the assessee before us. We find that as observed by the CIT(Appeals), NFAC and, rightly so, as per sub-section (7) of Section 154 of the Act, as no amendment under the said section shall be made after expiry of four years from the end of the financial year in which the order sought to be rectified was passed, therefore, the applications filed by the assessee seeking rectification of the orders passed by the DCIT, CPC-TDS u/s. 200A of the Act on 06.09.2014 by filing rectification letters dated 02.02.2022 for the aforementioned respective years were in itself not maintainable. No infirmity in the view taken by the CIT(Appeals), NFAC that as the applications filed by the assessee after expiry of more than seven years from the end of the financial year in which the order was sought to be rectified u/s. 154 of the Act were in itself barred by limitation, therefore, the same were not maintainable.
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