Time barred Section 115JB effect cannot be given by way of appeal effect

G. E. Conductors Pvt. Ltd Vs ACIT (ITAT Amritsar) Admittedly, while framing the assessment vide order u/s 143(3) dated 21/3/2014, the assessing officer did not make any reference to section 11 5JB or give any working of section 11 5JB either in the assessment order or the accompanying documents (APB, Pg. 3 to 10). In our view, it is an apparent mistake in the assessment order which ought to be rectified by way of an order under section 154 or section 263 of the Act. Again, the ld. CIT(A) disposing off the appeal vide order dated 8/5/2018, wherein the Section 11 5JB was not an issue in the gro...