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Rectification Application u/s 154 Valid: Filed Within Limitation Period, Challenges AO's Suo-Moto Order on Surcharge.
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....Rectification u/s 154 - period of limitation - original order passed by the AO dated 05/04/2011 - AO has already passed a suo-moto rectification order u/s 154 dated 18/03/2014 - Even though the surcharge was levied in terms of the first order, the order so sought to be rectified by the assessee is the rectified order dated 18/03/2014 wherein the surcharge continued to be levied on the assessee besides additional interest. Therefore, the rectification application dated 01/07/2016 is well within the limitation period as so prescribed and is not barred by limitation. - AT....