https://www.taxtmi.com/caselaws?id=446960 The dominant issue was limitation under s.154(7) for a rectification application concerning an intimation u/s 143(1). Applying SC law, the ITAT held the four-year period must be computed with reference to the relevant final communication giving rise to the actionable grievance, and not mechanically from the original 143(1) intimation date; the AO erred in ignoring the subsequent final CPC response issued on the assessee's objection. Consequently, the assessee's rectification application was held to be within time. On merits, since the first appellate authority had only remitted the matter to the AO to verify and allow eligible brought-forward losses, the ITAT found no infirmity in that direction and dismissed the revenue's appeal. en-us Wed, 13 Dec 2023 00:00:00 +0530 Fri, 26 Dec 2025 10:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446960 The dominant issue was limitation under s.154(7) for a rectification application concerning an intimation u/s 143(1). Applying SC law, the ITAT held the four-year period must be computed with reference to the relevant final communication giving rise to the actionable grievance, and not mechanically from the original 143(1) intimation date; the AO erred in ignoring the subsequent final CPC response issued on the assessee's objection. Consequently, the assessee's rectification application was held to be within time. On merits, since the first appellate authority had only remitted the matter to the AO to verify and allow eligible brought-forward losses, the ITAT found no infirmity in that direction and dismissed the revenue's appeal. Case-Laws Income Tax Wed, 13 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446960