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2023 (8) TMI 1249 - AT - Income TaxRectification of mistake u/s 154 - period of limitation - HELD THAT:- As following the decision of Sakseria Cotton Mills Ltd [1979 (2) TMI 17 - BOMBAY HIGH COURT] we hold that in the case limitation for expiry of 4 years for the purpose of section 154(7) of the Act has to be reckoned from the original assessment u/s 143(3) of the Act which is dated 21.11.2011 whereas the order u/s 154 has been passed on 29.06.2017, which is clearly beyond the period of four years specified and therefore, the 154 order passed by the AO is beyond the period of the limitation provided. Accordingly, same is invalid in law and thus it is quashed. The grounds of appeal of the assessee are accordingly allowed.
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