AO cannot use s.154 to exceed s.263 direction or revisit untargeted s.80IA deduction; rectification time-barred
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....The HC held that the AO cannot, by invoking s.154, effect rectification beyond the scope of the s.263 direction and cannot revisit a deduction under s.80IA which was neither the subject-matter of the s.263 proceedings nor of the appeal. Two assessment orders exist: the original order dated 10.02.2005 and the s.263 order dated 20.10.2011. The impugned rectification purportedly altering the 10.02.2005 assessment is time-barred because limitation under s.154(7) runs from 10.02.2005. The rectification order dated 28.03.2012 is therefore barred by limitation, and the ITAT's conclusion computing limitation from the original assessment was upheld.....
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