The assessment u/s 143(3) was completed on 21st March, 2014, the AO did not make any reference to S. 115JB or has given any working of S. 115JB either in the assessment order or the accompanying documents. While giving effect to the order of CIT(A) the Assessing Officer passed an order under section 154 assessing the income on book profit. The order of the Assessing Officer was affirmed by the CIT (A). On appeal the Tribunal held that even if there was a mistake, the same could not be rectified while giving appeal effect-Since the remedy available to the Revenue had already become time-barred. (AY. 2012-13)
G.E. Conductors (P) Ltd. v. ACIT (2022) 220 DTR 345 / 220 TTJ 1052 (Amritsar)(Trib)
S. 154 : Rectification of mistake-Mistake apparent from the record-Book profit-Order giving effect while framing assessment as per the direction of CIT(A)-Order time barred-Cannot be rectified. [S.115JB, 143(3), 250]