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    <title>2026 (4) TMI 470 - ITAT MUMBAI</title>
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    <description>Rectification cannot be used to reopen a concluded position on a disputed factual issue or to review an earlier acceptance under the income-tax law. The assessee&#039;s exemption under section 11 had originally been allowed after the return was filed within the extended CBDT timeline and Form 10B filing difficulties were explained. A later rectification denying the exemption merely revisited the same factual dispute and was beyond the scope of section 154, especially as no opportunity of hearing was granted. The rectification order was therefore invalid and the original intimation allowing the exemption was restored.</description>
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      <title>2026 (4) TMI 470 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=789401</link>
      <description>Rectification cannot be used to reopen a concluded position on a disputed factual issue or to review an earlier acceptance under the income-tax law. The assessee&#039;s exemption under section 11 had originally been allowed after the return was filed within the extended CBDT timeline and Form 10B filing difficulties were explained. A later rectification denying the exemption merely revisited the same factual dispute and was beyond the scope of section 154, especially as no opportunity of hearing was granted. The rectification order was therefore invalid and the original intimation allowing the exemption was restored.</description>
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      <pubDate>Thu, 12 Mar 2026 00:00:00 +0530</pubDate>
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