Debatable & contentious Issues cannot be Rectified under section 154

Sambros Tex Global Ltd Vs ACIT (ITAT Chennai)

Brief facts are that the assessee filed its return of income for the assessment year 2009-10 on 30.09.2009 and accordingly, scrutiny assessment was passed u/s.143(3) of the Act on 23.11.2011. Subsequently, the AO issued notice u/s.154 of the Act for the reason that prior period income of Rs.1 crore was not taxed u/s.115JB of the Act. The AO in his rectification order u/s.154 of the Act dated 29.03.2016 made addition of Rs.99.31 lakhs being prior year income of Rs.1 crore shown be

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