Time limit for filing application u/s 54 of the Act

Pls upload the order. Rectification can be made , there are specific provisions.

For which AY ?

Reason for correction?

Time limit for filing applicatio. under section 154 is still there.

In one group case, a survey was conducted under section 132 and after that block assessment was framed under section 153A for AY 1995-96 to 2001-02 in all the cases of that group. We approached Settlement Commission for all the group cases and AO passed the order giving effect to the settlement commission order in 2011 wherein the AO also levied surcharge. In 2014, the supreme court decided the identical matter and held that surcharge can't be levied in these cases but we forgot to file rectification application.

Finally, in 2018, we file the rectification application before the AO but the AO rejected the application stating that rectification right is barred by the limitation.

Is AO correct in his opinion??

Because, as I understand provision of subsection 8 of sec 154 supercedes the provision of 154(7).

please clarify.

thanks and regards,

Contact nearest tax consultant or professionals.

It's better to go through professionals for this kind of issues