2025 (9) TMI 244

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Adv. Madhur Agarwal a/w Adv. Jas Anghavi, Adv. Linzy Sharan and Adv. Punit Shah i/b. PDS Legal. For the Respondent Nos. 1 & 2: Adv. Yogeshwar S. Bhate. P. C. 1. Rule. Respondents waive service. With the consent of the parties Rule made returnable forthwith and heard finally. 2. The above Writ Petition is filed challenging (i) the impugned rectification order dated 9th February, 2024 pa....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....of JB Boda Insurance Brokers Pvt. Ltd. [one of the entities before the mergers], was not granted. 4. In light of this, the Petitioner on 27th September, 2023, filed a rectification application before Respondent No. 1 under Section 154 of the IT Act. By this rectification application, the Petitioner sought credit of the TDS issued in the name of JB Boda Insurance Brokers Pvt. Ltd. This rectifica....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., and after perusing the papers and proceedings in the Writ Petition, we are of the view that the 2nd Respondent misdirected himself when he calculated the period of limitation from the date when the order under Section 143(3) was passed. What was sought to be revised before the 2nd Respondent was the rejection of the Petitioners' rectification application, and which was decided on 9th February, 2....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nder Section 154 of the Act was passed on 9th February 2024 and the application under section 264 of the Act was filed on 13th January 2025, within one year." 7. In light of this aforesaid discussion, we hereby quash and set aside the impugned order dated 19th March, 2025 passed by the 2nd Respondent under Section 264 of the IT Act and remand the matter back to the 2nd Respondent to decide the ....