Assessment Order Rectification Invalid: Issued After 4-Year Limit u/s 154; Ambiguities Favor Assessee.

Validity of rectification order as barred by limitation - AO made additions after 4 years while passing rectification order u/s 154 - even if there be any ambiguity or doubt in drafting the assessment-order, it has to be resolved in favour of assessee and the revenue cannot take advantage of it for the simple reason that the AO, who is an officer of revenue, has drafted assessment-order. - AT .....

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