ITAT Quashes Section 154 Rectification as Section 270AA Immunity Gave Finality to Assessment

Nilgiri Dairy Farm Private Limited Vs DCIT (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT) quashed a rectification order passed under Section 154 of the Income-tax Act that denied the assessee the benefit of set-off of business losses against an addition of ₹1.77 crore. The original assessment had disallowed 5% of certain expenses on an estimated basis due to inadequate supporting details and incorrectly treated the amount as unexplained expenditure under Section 69C. Subsequently, the assessee obtained immunity under Section 270AA by accepting the assessment and refraining from filin...