Rectification order appeal not maintainable to challenge original assessment addition; substantive grievance had to be raised separately.

An appeal against a rectification order under section 154 was held not maintainable where the assessee's real grievance was against the original assessment addition under section 69A. The rectification only corrected a computation error and did not alter the substantive addition, so any challenge to that addition had to be brought in appeal against the assessment order itself. On that basis, the first appellate authority's dismissal of the appeal was upheld, while the assessee was left free to challenge the assessment order in accordance with law, subject to limitation.

---

---

Issues: Whether the appeal against the rectification order under section 154 was maintainable when the grievance of the assessee related to the original assessment order and not to the rectification granted by the Assessing Officer.

Analysis: The return had been processed and the assessment completed under section 143(3) of the Income-tax Act, 1961, with an addition under section 69A. The assessee's application for rectification was allowed, and only a computation error was corrected under section 154. The appeal before the first appellate authority was directed against the rectification order, not against the original assessment order. Since the rectification order did not disturb the substantive addition, any challenge to that addition had to be made in appeal against the assessment order itself. In these circumstances, the dismissal of the appeal by the first appellate authority was found to be proper. The assessee was left free to challenge the assessment order in accordance with law, subject to limitation.

Conclusion: The appeal against the rectification order was not maintainable to assail the original addition, and the dismissal by the first appellate authority was upheld.

---