Rectification Limitations: Section 154 Cannot Address Issues Evaluated in Original Assessment, Including Section 40A(3) Disallowances.

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....Scope of rectification u/s. 154 - The issue of disallowance u/s. 40A(3) and prior period expenses are beyond the scope of rectification u/s. 154 of the Act when the Ld.AO has thoughtfully considered these expenses and has made an ad-hoc disallowance of 10% while framing the original assessment. - AT....