https://www.taxtmi.com/caselaws?id=417582 The Tribunal ruled in favor of the assessee on all issues raised in the case. It held that the Assessing Officer cannot change the head of income in rectification proceedings under section 154, emphasizing the importance of procedural requirements such as issuing a show cause notice and providing a reasonable opportunity to be heard. Additionally, the Tribunal found that the rectification order was barred by limitation under Section 154(7) of the Act. The Tribunal allowed both appeals of the assessees, primarily based on the grounds of limitation and procedural fairness. en-us Mon, 24 Jan 2022 00:00:00 +0530 Tue, 25 Jan 2022 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417582 The Tribunal ruled in favor of the assessee on all issues raised in the case. It held that the Assessing Officer cannot change the head of income in rectification proceedings under section 154, emphasizing the importance of procedural requirements such as issuing a show cause notice and providing a reasonable opportunity to be heard. Additionally, the Tribunal found that the rectification order was barred by limitation under Section 154(7) of the Act. The Tribunal allowed both appeals of the assessees, primarily based on the grounds of limitation and procedural fairness. Case-Laws Income Tax Mon, 24 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417582