#Section 154 IT Act

ITAT Ahmedabad condones a 485-day delay in appealing a rectification order under Section 154 of the Income Tax Act, holding that natural justice mandates de novo adjudication where the substantive merits of the case remain unresolved. The ruling underscores that procedural delays cannot bar substantive justice if broader tax issues (e.g., Section 56(2) additions) are still pending.

ITAT Kolkata has ruled that errors in an income tax return - such as incorrect LTCG computation - can be corrected under Section 154 if apparent from the record, regardless of whether the rectification changes the total income. This affirms that the scope of rectification extends to the return itself, not just assessment orders, reinforcing natural justice and the tax officer’s duty to ensure accurate computation under CBDT Circular 14/1955.

ITAT Ahmedabad has ruled that an assessing officer cannot use rectification under Section 154 to convert income previously accepted as business income into unexplained income under Section 69A when the classification is genuinely debatable. This protects taxpayers from retrospective reclassification via procedural shortcuts, reinforcing that rectification is for clerical errors only - not for revisiting contested tax positions.

ITAT Pune prioritized substantive justice by condoning a 971-day delay in filing an appeal by a legal heir, remitting the case to CIT(A) for merits adjudication. The ruling underscores that procedural delays caused by the assessee's death should not bar access to appellate remedies under Section 154 of the Income Tax Act.