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2022 (11) TMI 1247 - AT - Income TaxRectification of mistake u/s 154 - expiry of time limit prescribed u/s 154(7) - claim of additional depreciation made first-time through rectification application after the expiry of time limit prescribed u/s 154(7) - statutory limit of four years from the end of the financial year - whether claim for additional depreciation u/s 32(1)(iia) of the Act is in modification of original claim made in the ITR or a fresh claim to testify its allowance through rectification application? - HELD THAT:- Since, the Ld. AR failed to bring on record any substantial evidence in support of allowability of belated claim made through belated application of rectification and in the absence of any order of relaxation from the CBDT, we beyond any iota of doubt are inclined to hold the orders of both the tax authorities free from any infirmity, ergo the ground number 3 and its counter parts stand adjudicated against the assessee.
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