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2026 Supreme(Online)(ITAT) 14388
आयकर अपीलय अधकरण ’बी’ यायपीठ, चेनई।
IN THE INCOME TAX APPELLATE TRIBUNAL
‘B’ BENCH: CHENNAI
ी इंतूरी रामा राव लेखा सद एवं ी मनुकु मार िगर, ाियक सद
BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND
SHRI MANU KUMAR GIRI, JUDICIAL MEMBER
आयकर अपील सं./ITA No 3966 /Chny/2025
नधारण वष/Assessment Years: 2016-17
Hitech Flyash India Private Limited,
2/101-5, Thiruchendur Road,
Muthiahpuram, Tuticorn,
Tamil Nadu-628005
v.
Assistant Commissioner of Income Tax,
Tirunelveli-627011,
[PAN: AABCH 7093 J]
(Appellant) (Respondent)
अपीलाथ क ओर से/Appellant by : Mr. J. Saravanan, Adv.
!यथ क ओर से /Respondent by : Ms. Gouthami Manivasagam, Addl. CIT
सुनवाई क तारख/Date of Hearing : 06.05.2026
घोषणा क तारख /Date of Pronouncement : 09.06.2026
आदेश / O R D E R
PER MANU KUMAR GIRI, JM:
The captioned appeal filed by the Assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), [hereinafter referred to as “CIT(A)”], ADDL/JCIT (A)-1, Pune, dated 24.10.2025 for the Assessment Year 2016-17.
2. The brief chronology of events leading to the present appeal is as under: -
| Date | Events |
|---|---|
| 10.10.2018 | Assessment order passed u/s. 143(3) of the Income-tax Act, 1961 pursuant to limited scrutiny under CASS. |
| 26.06.2021 | Assessment reopened u/s. 147 by issuance of notice u/s. 148 of the Act. |
| - | Assessment order passed u/s. 147 read with section 144B of the Act, wherein an addition of Rs.54,00,000/- was made. |
| 13.07.2023 | Rectification order passed by the Assessing Officer u/s. 154 of the Act. |
| 24.10.2025 | Order passed by the CIT(A) u/s. 250 of the Act. |
3. We have considered the material available on record and the submissions of the parties. From the above chronology, it is evident that the assessee did not challenge the assessment order passed u/s. 147 read with section 144B of the Act, whereby an addition of Rs.54,00,000/- was made by the Assessing Officer. The assessment order thus attained finality.
4. The present appeal emanates from the rectification order passed u/s. 154 of the Act dated 13.07.2023. The scope of proceedings u/s. 154 is limited to rectification of mistakes apparent from the record. In an appeal arising from such rectification proceedings, the assessee cannot be permitted to assail or reopen the merits of the original assessment order which was never challenged in accordance with law.
5. Since the assessee failed to avail the statutory remedy against the assessment order passed u/s. 147 read with section 144B of the Act, the addition of Rs.54,00,000/- cannot now be questioned indirectly in proceedings arising from the rectification order u/s. 154 of the Act. No independent cause of action concerning the said addition arises from the rectification order under challenge.
6. In view of the foregoing discussion, we find no merit in the appeal of the assessee. The grounds raised by the assessee are not maintainable in the present proceedings and are accordingly dismissed.
7. In the result, the appeal filed by the assessee is dismissed.
Order pronounced in the open court on the 09th day of June 2026, in Chennai.
