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2024 (1) TMI 207 - AT - Income TaxRectification u/s 154 - period of limitation - Deduction available u/s 10(10AA) - HELD THAT:- The fact that the assessee did not make any claim in his return of income is undisputed. It is true that after the judgment of the Tribunal in the case of Ram Kanwar Rana [2016 (6) TMI 687 - ITAT DELHI] the assessee became aware of the eligibility of the deduction available u/s 10(10AA) of the Act but that was on 16.06.2016 and the rectification application has been moved on 28.07.2020. Considering from all possible angles the application of the assessee is barred by limitation u/s 154 of the Act. Most importantly on the date of the processing of the return, there was no mistake apparent from record which could be rectified u/s 154 of the Act. The decisions relied upon by the Counsel are on a different set of facts mostly on the eligibility of the claim of deduction u/s 10(10AA) but the case of the assessee is the claim u/s 154 of the Act which according to our considered opinion is barred by limitation. We decline to interfere with the finding of the CIT(A). Appeal of the assessee is dismissed.
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