2026 (7) TMI 1155

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....g u/s 154 of the Income Tax Act [hereinafter referred as "The Act"]. 2. The brief facts of the case are that the assessee had filed its return of income for A.Y. 2020-21 on 08.01.2021 declaring Nil income. The return was processed u/s. 143(1) of the Act, on 23.12.2021. In the intimation order profit from business was computed by CPC at Rs. 7,60,72,928/- instead of Rs. 31,999/- after allowing set-off of brought forward loss and unabsorbed deprecation. The gross total income computed u/s. 143(1) was Rs. 7,60,54,744/- instead of Nil income, which has resulted in tax demand and interest of Rs. 2,66,70,190/-. Thereafter, the assessee had filed an application u/s. 154 of the Act, to rectify the mistake apparent from record in the intimation or....

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....A' of manufacturing account clause 4(A)(iv), 4(D), 6, 10(xii) and 12 of schedule Part-A of Trading account and clause 13, 14(xii), 15, 50, 53, 56 and 60 of schedule Part-A of Profit and loss account. Some of these clauses pertain to debits to manufacturing, trading and profit & loss accounts and some pertain to credit side of manufacturing trading and profit and loss accounts. He explained that totals of these clauses are calculated automatically and assessee is not allowed to mention totals manually. While processing the Income tax Return us 143(1), totals of clauses pertaining to credit side of manufacturing, trading and profit and loss accounts have been automatically captured and totals of clauses pertaining to debit side of manufacturi....

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.... JAO with a direction to examine the mistake in the intimation, if any. 7. We have considered submissions of the assessee. As explained the difference in the total income as per intimation vis-à-vis the ITR was due to certain arithmetical mistake in the manufacturing account. It transpires that the assessee had shown an opening stock of WIP of Rs. 66,74,588/- but the total opening inventory was wrongly taken at Nil in the ITR and this mistake continued in the intimation as well. On the other hand, the assessee had shown closing stock of WIP of Rs. 5,91,41,538/- but the total was taken as Nil in the ITR. However, the total of closing stock of WIP was rightly taken at Rs. 5,91,41,538/- in the intimation u/s. 143(1). These mistakes i....