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    <title>2019 (11) TMI 81 - ITAT DELHI</title>
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    <description>After reassessment under section 147 was completed on specified reasons, the Assessing Officer could not use section 154 to make a fresh addition for alleged closing stock discrepancy that was never addressed in the reassessment order. Section 147, read with Explanation 3, permits consideration of escaped income within reassessment proceedings, but that jurisdiction does not extend beyond the concluded reassessment. Rectification under section 154 is limited to a mistake apparent from the record and cannot be used to introduce a substantive new addition after reassessment has ended. The rectification order and resulting addition were held to be without jurisdiction and unsustainable.</description>
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      <title>2019 (11) TMI 81 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=387832</link>
      <description>After reassessment under section 147 was completed on specified reasons, the Assessing Officer could not use section 154 to make a fresh addition for alleged closing stock discrepancy that was never addressed in the reassessment order. Section 147, read with Explanation 3, permits consideration of escaped income within reassessment proceedings, but that jurisdiction does not extend beyond the concluded reassessment. Rectification under section 154 is limited to a mistake apparent from the record and cannot be used to introduce a substantive new addition after reassessment has ended. The rectification order and resulting addition were held to be without jurisdiction and unsustainable.</description>
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