Satish Cold Storage v. Dy. CIT (2022) 97 ITR 601 (SMC) (Lucknow) (Trib)

S. 154 : Rectification of mistake-Mistake apparent from the record-Industrial undertakings-Audit report not filed with return of income-Mistake rectified subsequently-Circular directing Assessing officers to allow rectification-Rectification application cannot be rejected [S.80IB, 143(1), Central Board Of Direct Taxes Circular No. 689, Dated 24-8-1994]

The Tribunal held that the Central Board of Direct Taxes Circular No. 689, dated August 24, 1994 ([1994 209 ITR (St.) 75), directed officers to allow rectification under section 154 where the audit report or other evidence could not be filed with the return of income but was filed later. Therefore, the application under section 154 was to be allowed. (AY.2017-18, 2018-19).