2022 (12) TMI 748

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ed by the assessee against the order of the ld CIT(A), Bhubaneswar in Appeal No. for the assessment year 2. Shri P.R.Mohanty, ld AR appeared for the assessee and Shri Kishore Chandra Mohanty, ld Sr. DR appeared for the revenue. 3. It was submitted by ld AR that the assessee is an individual, who is deriving income from salary rendering services outside India in UAE as an Architect during the rel .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... 2015 after a delay of nearly 7 years. The rectification application came to be rejected by the Assessing Officer on the ground that it was time barred under the provisions of section 154(7) of the Act. It was the submission that even the ld CIT(A) dismissed the assessee's appeal on the ground that the rectification application was beyond time. It was the submission that in respect of such situatio .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ough it is beyond four years of limitation in view of CBDT Circular No.4 of 2012 dated 20.6.2012. 5. We have considered the rival submissions. Admittedly, the assessee individual is a non-resident Indian and the facts clearly show that the return has been filed with mistakes. These mistakes can admittedly be rectified by filing a rectification application. The rectification application admittedly .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X