2025 (11) TMI 277

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....celess Appeal Centre, Delhi (NFAC) [ld. CIT(A)] dated 10.10.2022 wherein the appeal filed by the assessee against the rectification order dated 13.6.2016 passed u/s. 154 of the Income-tax Act, 1961 [the Act] dated 13.6.2016 was allowed. 2. Therefore the ld. AO is aggrieved and is in appeal before us on the following grounds of appeal :- "(i) Whether on the facts and in circumstances of the case and in law, the Ld.CIT[A] NFAC erred in holding the issue to be a mistake apparent from record & setting aside the rejection of rectification application u/s 154 by the AO, by ignoring the fact that the issue involved is debatable in nature and not a mistake apparent from record? ii Whether on the facts and in circumstances of th....

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....t was completed u/s. 143(3) of the Act dated 31.12.2009. 4. Subsequently the assessee filed a rectification application u/s. 154 on 19.3.2012 pointing out the mistake apparent from the record in not allowing the deduction u/s. 36(1)(vii) in respect of non-rural debts written off by the assessee bank. The AO dismissed the application for rectification. 5. The assessee preferred appeal before the ld. CIT(A). The ld. CIT(A) noted that the rectification application u/s. 154 rejected by the AO is not sustainable. Therefore the ld. AO is in appeal before us. 6. The ld. DR supported the order of the ld. AO and the ld. AR supported the order of the ld. CIT(A). 7. We have carefully considered the rival contentions and perused the orders ....