HC held the rectification order u/s 154 invalid and non est as it did not bear a DIN in the manner mandated by CBDT Circular 19/2019 and thus was deemed never to have been issued. On facts, HC inferred that the order was backdated to 29.03.2024 to avoid limitation, since a notice proposing rectification u/s 154(3) was issued only on 20.06.2024, after expiry of the four-year period u/s 154(7) on 31.03.2024. HC further held that a separate notice granting opportunity of hearing under s.154(3) was mandatory as the rectification increased total income. The impugned rectification order was quashed and set aside.
HC held the rectification order u/s 154 invalid and non est as it did not bear a DIN in the manner mandated by CBDT Circular 19/2019 and thus was deemed never to have been issued. On facts, HC inferred that the order was backdated to 29.03.2024 to avoid limitation, since a notice proposing rectification u/s 154(3) was issued only on 20.06.2024, after expiry of the four-year period u/s 154(7) on 31.03.2024. HC further held that a separate notice granting opportunity of hearing under s.154(3) was mandatory as the rectification increased total income. The impugned rectification order was quashed and set aside.
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