https://www.taxtmi.com/caselaws?id=781187 HC held that the AO could not use a Section 154 rectification of the 20.10.2011 order to alter issues not subject to the Section 263 direction, specifically the Section 80IA deduction which was unchallenged in the original 10.02.2005 assessment. The court found the purported rectification was effectively aimed at the 10.02.2005 order, so the four-year limitation under Section 154(7) runs from 10.02.2005. Consequently the rectification dated 28.03.2012 was time-barred, and the ITAT's view to that effect was upheld. en-us Tue, 23 Sep 2025 00:00:00 +0530 Tue, 11 Nov 2025 10:39:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781187 HC held that the AO could not use a Section 154 rectification of the 20.10.2011 order to alter issues not subject to the Section 263 direction, specifically the Section 80IA deduction which was unchallenged in the original 10.02.2005 assessment. The court found the purported rectification was effectively aimed at the 10.02.2005 order, so the four-year limitation under Section 154(7) runs from 10.02.2005. Consequently the rectification dated 28.03.2012 was time-barred, and the ITAT's view to that effect was upheld. Case-Laws Income Tax Tue, 23 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781187