9911796707
TMI Blog2022 (2) TMI 983X X X X Extracts X X X X X X X X Extracts X X X X ..... mount as shown in the original return of income i.e. ₹ 15,306/- . In our considered view, the aforesaid facts duly lends credence to the claim of the assessee that the income reflected in the revised return of income on account of a mistake which was glaring on the very face of it was therein wrongly mentioned. We are of a strong conviction that the income returned by the assessee in his revised return at ₹ 40,42,980/- suffered from a mistake which was apparent, patent, obvious and glaring from record, which therein rendered the same amenable for rectification u/s.154 of the Act. We, thus, not being able to persuade ourselves to subscribe to the summarily dismissal of the assessee s application u/s.154 of the Act by the Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt year 2010-11 on 24.07.2020, declaring a total income of ₹ 4,04,298/-, against which the tax liability of ₹ 15,306/- was reflected. Subsequently, a revised return of income was filed on 26.07.2010, disclosing an income of ₹ 40,42,980/-, against which the tax liability ₹ 15,306/- (as reflected in the original return of income) was reflected. On the basis of the revised return of income a demand of ₹ 13,23,120/- was raised against the assessee. On learning about the aforesaid demand, the assessee approached the ITO-2, Bilaspur, who therein scaled up the outstanding demand to an amount of ₹ 25,85,818/-. Backed by the aforesaid facts, the assessee filed with the A.O an application u/s.154 of the Act, wherei ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e-filing account and was duly verified by him, therefore, the same could not have been ignored by the Assessing Officer/CPC. In the backdrop of his aforesaid observation, the CIT(A) was of the view that the action of the Assessing Officer in rejecting the application filed by assessee u/s 154 of the Act seeking rectification of a mistake in the revised return of income did not suffer from any infirmity. 5. Being aggrieved the assessee has assailed the impugned order passed by the CIT(A) upholding the rejection of his application for rectification of a mistake in the revised return of income by the Assessing Officer before us. Controversy involved in the present appeal lies in a narrow compass, i.e., as to whether or not the CIT (Appeals ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve a strong conviction that there is substance in the claim of the assessee that in his revised return of income the gross total income was wrongly stated at ₹ 40,42,980/- as against income of ₹ 4,04,298/- (as originally returned), which mistake had crept in by wrongly suffixing one Zero to the amount of the income as originally returned. Our aforesaid conviction is supported by the very fact that even in the revised return of income the tax liability on the amount of income so returned i.e. ₹ 40,42,980/- had been reflected at the same amount as shown in the original return of income i.e. ₹ 15,306/- . In our considered view, the aforesaid facts duly lends credence to the claim of the assessee that the income reflec ..... X X X X Extracts X X X X X X X X Extracts X X X X
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