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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The Assessing Officer (AO) denied interest u/s 244A for the period from April 2006 to January 2008, citing delay attributable to the assessee in filing the return. The assessee had filed the return on 08/01/2008, after the due date of 30/09/2006. The AO later invoked Section 154 to rectify the alleged mistake of granting excess interest for the 22-month period, assuming jurisdiction erroneously. However, the Tribunal held that such a mistake cannot be rectified u/s 154, as the proposed amendment is effective from 01/06/2016, while the return was filed on 08/01/2008. Additionally, the payer had deducted tax at source, benefiting the revenue irrespective of the return filing date. The refund with interest was granted after the assessee's appeal, and the Coordinate Bench ruled against rectification u/s 154 in similar cases.
The Assessing Officer (AO) denied interest u/s 244A for the period from April 2006 to January 2008, citing delay attributable to the assessee in filing the return. The assessee had filed the return on 08/01/2008, after the due date of 30/09/2006. The AO later invoked Section 154 to rectify the alleged mistake of granting excess interest for the 22-month period, assuming jurisdiction erroneously. However, the Tribunal held that such a mistake cannot be rectified u/s 154, as the proposed amendment is effective from 01/06/2016, while the return was filed on 08/01/2008. Additionally, the payer had deducted tax at source, benefiting the revenue irrespective of the return filing date. The refund with interest was granted after the assessee's appeal, and the Coordinate Bench ruled against rectification u/s 154 in similar cases.
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