TMI Blog2023 (4) TMI 744X X X X Extracts X X X X X X X X Extracts X X X X ..... ation u/s.154 on 31.01.2018 i.e. much after lapse of four years from the end of the financial year in which intimation u/s.143(1) of the Act dated 13.12.2010 was issued by the A.O. As the aforesaid application was filed by the assessee u/s.154 beyond the stipulated time period as provided in sub-section (7) of Section 154 of the Act, therefore, the same was rightly held by the A.O as not maintaina ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the following grounds of appeal: 1. The order of the ld. CIT(A) is bad in law and on facts. 2. The ld. CIT(A) erred in not considering the rectification application when the rights of rectification were transferred to him which was filed within the time limit. 3. The learned CIT(A) erred in not considering my rectification application for requesting allowances of depreciation which has b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ht to be amended was passed, therefore, on the said count itself the same was dismissed by the A.O vide his order dated 18.07.2018. 4. Aggrieved the assessee carried the matter in appeal before the CIT(Appeals) but without any success. 5. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before me. As the assessee appellant despite having been i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same was rightly held by the A.O as not maintainable. For the sake of clarity sub-section (7) of Section 154 of the Act is culled out as under: (7) Save as otherwise provided in section 155 or sub-section (4) of Section 186 no amendment under this section shall be made after the expiry of four years [from the end of the financial year in which the order sought to be amended was passed]. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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