The ITAT Delhi addressed the issue of rectification of mistake...

The ITAT Delhi addressed the issue of rectification of mistake u/s 154 beyond the limitation period. The AO failed to fulfill the statutory duty by not passing an order on the application u/s 154 within the prescribed time. The tribunal held that the appellant had the right to appeal u/s 246A due to the AO's failure. The CBDT circular allows corrections in disputed arrear demands even after the limitation period. The tribunal directed the AO to consider and dispose of the application filed u/s 154 in 2014. The tribunal emphasized that failure to fulfill statutory obligations cannot prejudice the taxpayer's interests.