Rectification orders cannot reopen an unchallenged original intimation unless a clear apparent mistake or fresh prejudice is shown.

A later rectification or calculation order under section 154 could not be used to reopen an unchallenged original intimation under section 200A levying late filing fee under section 234E. Because the earlier intimation had not been appealed against and no mistake apparent from the record or fresh prejudice from the rectification order was shown, the appeals were held not maintainable and were dismissed on the facts.

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Issues: Whether appeals against rectification orders under section 154 of the Income-tax Act, 1961 were maintainable where the original intimation under section 200A of the Income-tax Act, 1961 had not been challenged and no mistake apparent from the record was shown.

Analysis: The appeals arose from orders showing the exact amount due pursuant to earlier intimations levying late filing fee under section 234E of the Income-tax Act, 1961. The earlier intimations under section 200A had not been appealed against, and the rectification proceedings were not shown to have altered the original demand or caused any fresh prejudice. The request made in 2021 was only for calculation of the updated amount and interest, and it did not disclose any apparent mistake in the rectification order when compared with the original intimation. The attempt to use the later order under section 154 to reopen the original levy was therefore not accepted.

Conclusion: The appeals were not maintainable on the facts and were dismissed.

Ratio Decidendi: A later rectification or calculation order cannot be independently assailed to reopen an unchallenged original intimation unless a specific mistake apparent from the record or fresh prejudice arising from that order is shown.

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