https://www.taxtmi.com/caselaws?id=445438 ITAT Delhi ruled in favor of a foreign company regarding rectification under section 154 for incorrect income determination. The CPC failed to consider revised Form 26AS showing reduced income of Rs. 2,71,80,917 due to revised TDS filings by deductors. CIT(A) incorrectly rejected the rectification request, arguing section 143(1) only permits additions, not reductions to declared income. ITAT held that section 154 allows correction of apparent mistakes on record, including income reduction under section 154(5). The tribunal emphasized revenue cannot be unjustly enriched and assessed income can fall below returned income in genuine cases. AO was directed to determine correct income of Rs. 2,90,10,368 and grant appropriate TDS credit of Rs. 29,78,210. en-us Tue, 10 Oct 2023 00:00:00 +0530 Wed, 08 Nov 2023 09:10:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445438 ITAT Delhi ruled in favor of a foreign company regarding rectification under section 154 for incorrect income determination. The CPC failed to consider revised Form 26AS showing reduced income of Rs. 2,71,80,917 due to revised TDS filings by deductors. CIT(A) incorrectly rejected the rectification request, arguing section 143(1) only permits additions, not reductions to declared income. ITAT held that section 154 allows correction of apparent mistakes on record, including income reduction under section 154(5). The tribunal emphasized revenue cannot be unjustly enriched and assessed income can fall below returned income in genuine cases. AO was directed to determine correct income of Rs. 2,90,10,368 and grant appropriate TDS credit of Rs. 29,78,210. Case-Laws Income Tax Tue, 10 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445438