Time barred Section 115JB effect cannot be given by way of appeal effect

Admittedly, while framing the assessment vide order u/s 143(3) dated 21/3/2014, the assessing officer did not make any reference to section 11 5JB or give any working of section 11 5JB either in the assessment order or the accompanying documents (APB, Pg. 3 to 10). In our view, it is an apparent mistake in the assessment order which ought to be rectified by way of an order under section 154 or section 263 of the Act. Again, the ld. CIT(A) di

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