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TMI Blog2024 (10) TMI 914X X X X Extracts X X X X X X X X Extracts X X X X ..... sec.154 rectification petition thereby followed by re-computation of her taxable income either. That being the case, we quote TS Balram, ITO vs. Volkart Brothers [ 1971 (8) TMI 3 - SUPREME COURT] that the assessee s sole ground in the instant appeal in fact involve detailed investigation/enquiries which is no more permissible u/sec.154 rectification proceedings as the latter provision is meant to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng her sec.154 rectification, the Revenue invited our attention to the learned CIT(A) s lower appellate discussion to this effect reading as under : 5. DECISION: 5.1. I have carefully considered the Order u/s. 154 of the I.T. Act, submission and the statement of facts filed by the appellant. In the case of the appellant, order u/s. 154 of the Income Tax Act dated 13.01.2020 was passed by the ITO, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the learned Assessing Officer passed a Rectification order on 13.01.2020 deleting the addition. The Assessing Officer observed that the assessee had borrowed Rs. 7,20,42,195/- during this year and paid interest to the tune of Rs. 66,67,567/-. The learned Assessing Officer further observed that the assessee is keeping fixed deposit with various bank which fetch lesser interest. He made an addition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee. 2. The assessee filed a rectification letter dated 07.01.2020 stating that the amount of Rs. 4,63,000/- was paid from the branch of the business. The consolidated day book shows payment of Rs. 9,91,103.78 to the bank on 11.11.2016 which includes cash payment of Rs. 4,63,000/- made from the branch. The details filed by the assessee were verified. The contention of the assessee appears to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... relates to order u/s. 143(3), this appeal becomes infructuous and treated as dismissed. 3. Suffice to say, it has already come on record that the learned assessing authority had duly accepted the assessee s sec.154 rectification petition thereby followed by re-computation of her taxable income either. That being the case, we quote TS Balram, ITO vs. Volkart Brothers [1971] 82 ITR 50 (SC) that the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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