Section 154 Can’t Be Used to Rework 36(1)(viia)(c) vs 36(1)(viii) – Revenue’s Rectification Knocked Out

JCIT Vs India Infrastructure Finance Company Limited (ITAT Delhi) ITAT Delhi dismissed the Revenue’s appeal for AY 2017-18 in India Infrastructure Finance Company Ltd., holding that the recomputation of deductions u/s 36(1)(viia)(c) and 36(1)(viii) through s.154 was impermissible. The AO, by invoking s.154, sought to reorder the sequence of deductions and reduced the combined claim by ₹12.16 crore, relying on Rural Electrification Corporation (ITAT Delhi). CIT(A) deleted the rectification, noting that the assessee had computed 36(1)(viia)(c) @ 5% on total income after allowing deduction u/...