2022 (5) TMI 368

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....case are the assessee filed its return of income for the assessment year 2014-15 on 25.11.2014 admitting an income of Rs..72,321,810/-. The case was selected for limited scrutiny. After considering the submissions of the assessee and verifications of books of account, etc., the Assessing Officer has completed the assessment order under section 143(3) of the Income Tax Act, 1961 ["Act" in short] on 24.12.2016. 2.1 The return filed by the assessee was picked up for limited scrutiny to verify a number of issues including high interest expenditure against new capital added in work in progress or addition to fixed assets. The Assessing Officer Smt. A Soranam, Assistant Commissioner of Income Tax, Non Corporate Circle-3, Madurai completed the ....

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....ord. Accordingly your petition for rectification u/s 154 is disposed off." 3. The assessee carried the matter in appeal before the ld. CIT(A) by raising following grounds of appeal: 1) The learned Assistant Commissioner of Income Tax while stating that Section 154 of the IT Act does not empower an Assessing Authority to review and revise an assessment made by him and to pass order u/s 154 did not deny in the impugned proceedings that Section 154 stipulates that an Assessing Authority shall make such amendment in the order passed by the Assessing Authority rectifying any such mistake which has been brought to its notice by an assessee and that such amendment of an order would not amount to review or revision of such an order. ....

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.... in regard to the admissible claim for deduction of Rs.8,96,649/- above referred to at the lime of hearing in the assessment order constituted a mistake apparent on the face of the disputed order passed u/s 143(3) of the I.T. Act and allowed the petition filed by the appellant u/s 154 of the I. T. Act. 5) It is, therefore, prayed that the mistake apparent on the face of the assessment order be ordered to be amended and the claim for deduction of Bank interest amounting to Rs.8,96,649/- be ordered to be allowed from the total income determined by the learned Assessing Officer. 3.1 After considering the submissions of the assessee, the ld. CIT(A) has observed as under: "8. I have considered the order passed u/s 154 and th....