Section 154(1A) bars rectification of an issue already decided in appeal, even when relief was only partial.

Section 154(1A) bars rectification where the same issue has already been considered and decided in appeal, even if the appellate authority allowed it only partly. The disputed exchange-rate fluctuation loss had been adjudicated by the appellate authority in favour of both sides in part, so it fell within the statutory bar. The Assessing Officer could not reopen that matter through a rectification notice under section 154 directed at an intimation under section 143(1)(a), and the notice was quashed.

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Issues: Whether a notice issued under section 154 of the Income-tax Act, 1961 to rectify an intimation under section 143(1)(a) could survive when the very matter had already been considered in appeal and partly allowed by the appellate authority, having regard to the bar under section 154(1A).

Analysis: The disputed item relating to loss on account of exchange rate fluctuation had already formed the subject-matter of appellate scrutiny, and the appellate authority had adjudicated it partly in favour of the assessee and partly in favour of the Department. On that basis, the matter was one that had been "considered and decided" within the meaning of section 154(1A). A narrow reading that partial allowance meant no decision had been rendered was rejected. The statutory bar under section 154(1A) prohibited rectification by the Assessing Officer in respect of such a matter, and the rectification notice could not be sustained.

Conclusion: The notice under section 154 was invalid and was quashed.

Final Conclusion: The assessee succeeded and the rectification proceedings initiated on the impugned notice were set aside.

Ratio Decidendi: Where an issue has been adjudicated in appeal, even partly, it is a matter considered and decided for the purpose of section 154(1A), and rectification on that issue by the Assessing Officer is barred.

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