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TMI Blog2022 (12) TMI 748X X X X Extracts X X X X X X X X Extracts X X X X ..... ification application admittedly is not being considered on account of the limitation provided u/s.154(7) - In view of the submissions made by both the sides and considering the Circular No.4 of 2012 dated 20.6.2012 issued by the CBDT, the issues in its appeal are restored to the file of the AO for readjudication of the rectification application on merits. AO is at liberty to examine whether th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Shri P.R.Mohanty, ld AR appeared for the assessee and Shri Kishore Chandra Mohanty, ld Sr. DR appeared for the revenue. 3. It was submitted by ld AR that the assessee is an individual, who is deriving income from salary rendering services outside India in UAE as an Architect during the relevant assessment year. The assessee had authorized M/s. D.M.Associates, a Chartered Accountant Firm at Bhu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fficer on the ground that it was time barred under the provisions of section 154(7) of the Act. It was the submission that even the ld CIT(A) dismissed the assessee s appeal on the ground that the rectification application was beyond time. It was the submission that in respect of such situation, the CBDT has issued a circular No.4 of 2012 dated 20.6.2012, wherein, the CBDT has directed that the li ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We have considered the rival submissions. Admittedly, the assessee individual is a non-resident Indian and the facts clearly show that the return has been filed with mistakes. These mistakes can admittedly be rectified by filing a rectification application. The rectification application admittedly is not being considered on account of the limitation provided u/s.154(7) of the Act. However, in view ..... X X X X Extracts X X X X X X X X Extracts X X X X
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