Dismissing the appeal the Tribunal held that  while exercising power under section 154 read with section 143(3) of the Act, the Assessing Officer had not gone back to reconsider the issues examined under section 143(3) and make an addition thereupon. It was not a case where rectification power was exercised consequent to any change of law or applying a different proposition of law than one considered while framing the assessment under section 143(3) of the Act. The rectification order made it apparent that the income determined in intimation under section 143(1) was taken as the income for making further additions under the section 143(3) assessment. That was a mistake apparent from record as the intimation under section 143(1) stood final after withdrawal of the appeal by the assessee. Accordingly, the difference between the returned income of Rs. 18,10,42,260 and the assessed income under section 143(1) of Rs. 30,93,07,020, was erroneously ignored while passing order under section 143(3). Therefore, the Assessing Officer had committed no error in exercising the rectification powers under section 154. Where the additions made under the intimation under section 143(1) and those made under section 143(3) were on different issues and heads, the intimation under section 143(1) of the Act stood final after withdrawal of the appeal by the assessee, and there was no merger of the two orders. The addition was made in intimation under section 143(1) of the Act with regard to disallowances on account of delayed contribution to the provident fund and employees’ State insurance and the house property income. In the scrutiny assessment these issues were not under examination so as to say that while exercising rectification powers the Assessing Officer had made rectification due to any change in opinion of law or fact. Thus, the order of the Commissioner (Appeals) was sustained.(AY. 2017-18)