CPC processed the return of income, and intimation u/s. 143(1) of the Act was issued on 05.03.2012. The AO passed a rectification order on 20.06.2016. The period for passing the rectification order was four years from the end of the financial year in which the order sought to be amended. Under section 154(7), the time to pass the order had expired on 31.03.2016. The date of the original order is the commencing point of limitation, irrelevant to the subsequent rectification or subsequent application. Hence, the order passed beyond 31.03.2015 is barred by limitation. (AY. 2003-04)
P. S. Jagdish v. Dy. CIT (2022) 216 TTJ 500 / 211 DTR 153 (Chennai)(Trib.)/Shekar P. S. v. Dy. CIT (2022) 216 TTJ 500 / 211 DTR 153 (Chennai)(Trib)
S. 154 : Rectification of mistake-The date of the original order is the commencing point of limitation, irrelevant to the subsequent rectification or subsequent application. Hence, the order passed beyond 31.03.2015 is barred by limitation. [S. 143(1), 154(7)]