2022 (12) TMI 641

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.... ORDER PER BENCH This is an appeal filed by the assessee against the order dated 9.6.2022 of the ld CIT(A), Kolkata-22, in Appeal No.ITBA/APL/S/250/2022-23/1043389940(1) for the assessment year 2009-2010. 2. Shri P.R.Mohanty, ld AR appeared for the assessee and Shri Charan Dass, Sr. DR appeared for the revenue. 3. It was submitted by ld AR that the assessee is an individual, who is ....

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....e assessee came to know the mistake and filed a rectification application on 20.11.2015 after a delay of nearly 7 years. The rectification application came to be rejected by the Assessing Officer on the ground that it was time barred under the provisions of section 154(7) of the Act. It was the submission that even the ld CIT(A) dismissed the assessee's appeal on the ground that the rectification ....

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....red to the file of the AO for verification, examination and adjudication on merits though it is beyond four years of limitation in view of CBDT Circular No.4 of 2012 dated 20.6.2012. 5. We have considered the rival submissions. Admittedly, the assessee individual is a non-resident Indian and the facts clearly show that the return has been filed with mistakes. These mistakes can admittedly be re....