2020 (12) TMI 603

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....as mistake apparent from record u/s.154 in respect of interest income which was duly considered in the agreed addition made by the learned AO. 2. Ld. CIT(A) erred in law and on facts in not appreciating that the total addition of Rs. 48,40,203/- was arrived at after due consideration of returned income of the appellant and accepted by the assessing officer. Any change in the said offer by the appellant and acceptance by the Id AO would not be a mistake apparent from record and will be a matter of debate and discussion. 3. The addition of Rs. 22,54,821/-u/s.154 is without the proper jurisdiction not being a mistake apparent from record may kindly be cancelled. 4. The appellant craves to add, alter, modify or substi....

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....t include income from other sources mainly on account of bank FDR interest. The A.O. had noticed that the said income from other sources which was also deducted as income returned from the business income offered to tax by the appellant of Rs. 1,46,15,111/- while arriving at addition to income returned. In view of the above facts, the AO had held that there is mistake apparent from record that the income from other sources of Rs. 22,54,821/- was remained to be assessed in the assessment order u/s.143(3) dated 22.08.2012. The AO has accordingly made addition of Rs. 22,54,821/- in the order passed u/s.154 of the Act." 4. That during the course of appellate proceedings, the assessee contended that the specific amount of Rs. 48,40,2....

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....tracts @2.22% 12,24,101/- Total 1,46,15,111/- Less: Income declared 98,00,250/- Addition 48,14,861/- In the above computation the profit from contract business was offered to tax at Rs. 1,46,15,111/- which does not include income from other sources Rs. 22,54,821/-. Therefore, the contention of the appellant is rejected. 9. In the result, the appeal is dismissed." 5. We have perused the relevant documents on records specifically assessment order, rectification order u/s.154 of the Act and the order of the Ld. CIT(Appeal) confirming the said rectification order wherein the addition of Rs. 22,54,821/- was confirmed. It is noticed that the assessee filed return declaring total income of Rs. 98,00,250/-.....