Hariom Biotech Agri Farming Vs DCIT (ITAT Nagpur)
In the case of Hariom Biotech Agri Farming Vs DCIT, the ITAT Nagpur addressed whether rectification under Section 154 of the Income Tax Act was mandatory for the Assessing Officer when clear data is unavailable. The dispute arose from the assessment for the year 2018-19, where the Central Processing Centre (CPC) had processed the assessee’s return but did not grant an exemption for agricultural income amounting to Rs. 1,15,69,581, which the assessee claimed as exempt. The CPC’s rejection was based on the omission of details in the return’s Schedule EI. The assessee’s appeal was dismissed by the CIT(A), who found no basis for rectification under Section 154 due to the absence of a clear mistake in the CPC’s processing. The ITAT upheld this decision, emphasizing that rectification is not obligatory if the error cannot be clearly identified from the data available. The assessee’s failure to file a revised return and the inability to address the error further contributed to the dismissal of the appeal. The ITAT concluded that without a manifest error, rectification under Section 154 is not warranted, thus affirming the CIT(A)’s dismissal of the appeal.
FULL TEXT OF THE ORDER OF ITAT NAGPUR
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