Section 154: AO cannot revise matter decided in appeal/revision

Nikon India Pvt. Ltd. Vs DCIT (ITAT Delhi)

Section 154(1A) lays down that rectification can be done for any matter other than the matter considered and decided in appeal/revision. Thus, whene any matter had been considered and decided in any proceeding by way of appeal or revision, rectification of such matter cannot be done by TPO/Assessing Officer under Section 154 of the Income Tax Act, 1961.

The said position is clear in terms of Section 154(1A) of the Act wherein it has been laid that

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