Held that in the absence of anything to prove that the intimation under S. 143(1) was served on the assessee, there is no question of calculating the period of limitation of four years for rectification thereof under s. 154 from the date of passing of intimation and, therefore, the application seeking rectification of said intimation could not be rejected as time-barred. (AY. 2010-11 to 2013-14)
Shree Jay Limbach Co-Operative Credit Society Ltd. v. ITO (2024) 229 TTJ 100 / 236 DTR 273 / 38 NYPTTJ 391(SMC ) (Ahd)(Trib)
S. 154 : Rectification of mistake-Mistake apparent from the record-Limitation-Non-service of intimation under S. 143(1)-The four year limitation seeking rectification starts ticking the moment the assessee is in receipt of the order-Rejection of application being time barred is not justified.[S.80P(2), 143(1), 154(7)]
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