Assessee wins rectification appeal under Section 154 for wrong column entries in original return

The ITAT Bangalore allowed the assessee's appeal for statistical purposes in a rectification matter under section 154. The assessee had filed an original return showing NIL income with erroneous figures in wrong columns, then filed a revised return on the same day claiming refund of Rs. 55,623. The CPC processed only the original return. The ITAT held that placing figures in wrong columns constituted a mistake apparent from record. Citing CBDT Circular No.14 of 1955, the matter was remitted back to the AO for rectifying the mistake in the original return and deciding as per law.

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Issues involved:
The appeal filed against the Order of CIT(Appeals) for the AY 2013-14 on grounds of incorrect processing of returns and refusal of rectification request.

Details of the Judgment:

1. Grounds 1-4 Rejection by A.O. and CIT(Appeals):
The assessee filed the original return of income on 29.10.2013, followed by a revised return on the same day. The CPC processed the original return, raising a demand. The rectification request was rejected by the AO and CIT(Appeals) stating no mistake apparent on record. The appellant's contention of technical mistake and filing a revised return was not considered, leading to the rejection of the appeal.

2. Submission by Appellant and AO's Decision:
The appellant submitted that errors in the original return were rectified in the revised return filed on the same day, resulting in a loss. Although the revised return was not authenticated by sending ITR-V to CPC, it was furnished to the AO, justifying rectification. The AO's refusal based on lack of authentication was challenged by citing relevant provisions and circulars.

3. Appellant's Argument and Remittance of the Case:
The appellant, a Charitable Trust, highlighted the mistake in filling figures in the return and the subsequent rectification request. Referring to CBDT Circular No.14 of 1955, assistance to taxpayers was emphasized. The case was remitted back to the AO for rectifying the mistake in the original return, considering the appellant's submissions and legal provisions.

4. Decision and Direction for Further Proceedings:
The appeal was allowed for statistical purposes, directing the AO to rectify the mistake in the original return and decide the issue in accordance with the law. The appellant was instructed to provide necessary documents and cooperate for a prompt resolution.

This judgment emphasizes the importance of rectifying mistakes in returns, considering technical errors, and providing taxpayers with a fair opportunity to address issues in compliance with legal provisions and circulars.

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