ITAT Upholds Section 154 Rectification as TOLA Extended Limitation for Rectification Proceedings

Jalgaon Peoples Co-op. Bank Limited Vs ITO (ITAT Pune) The appeal before the Income Tax Appellate Tribunal, Pune Bench, concerned Assessment Year 2015-16 and challenged the validity of a rectification order passed under Section 154 read with Section 143(1) of the Income Tax Act, 1961. The principal issue was whether the rectification order dated 17.09.2021 was barred by limitation under Section 154(7) and whether the Assessing Officer was justified in reducing the brought forward business loss claimed by the assessee. The assessee had originally filed its return of income on 29.09.2015 declari...