Section 154 Limits: No New Claims; Section 10(23C)(iiiad) Exemption Not Allowed; Sections 11 & 12 Withdrawal Invalidates Report.

Rectification application u/s 154 - exemption u/s 10(23)(C)(iiiad) - The scope of Section 154 is very narrow and restricted to only correcting mistakes apparent from record, and in case if the claim of the assessee requires long drawn deliberations and reasoning , it cannot be covered u/s 154. Thus, in our considered view , setting up of a new claim of exemption u/s 10(23C)(iiiad) for the first time through a rectification application u/s 154 of the 1961 Act is itself not permissible keeping in view the limited and narrow mandate of Section 154. Also that now withdrawing the exemption claim u/s 11 and 12 by filing rectification application u/s 154 , will falsify the accountants report u/s 12A(b) filed along with the return of income. - AT .....

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