2026 (4) TMI 1025

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....d against the order dated 29-09- 2025 passed by Addl/JCIT(A)-5, Mumbai for assessment year 2012-13. 2. The grounds of appeal are as under:- "1. The learned CIT(A) erred in confirming the action of the Assessing Officer in rejecting the rectification application u/s 154 on the ground of limitation u/s 154(7). 2. The learned CIT(A) failed to appreciate that the rectification ord....

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....udicial precedents, including ITAT Ahmedabad ruling in Liberty Pesticides & Fertilizer Ltd. v. ACIT, holding that rectification cannot be rejected as time-barred where the order was never served on the assessee. 7. The demand of Rs. 1,70,260 raised without granting tax credit is unjust, illegal and liable to be deleted. 8. The appellant reserves the right to add, amend, alter or ....