Charging of Short Gross Tax liability Determined u/s 5(3) by CIT(A) is Final and Non-Revisable: Delhi HC quashes Rectification notice u/s 154

The Delhi High Court has ruled that the determination of gross tax liability under Section 53 by the Commissioner of Income Tax (Appeals) [CIT(A)] is final and cannot be revised. The court quashed a rectification notice issued under Section 154, stating that once the tax liability is determined by the CIT(A), it cannot be altered except through an appeal. The judgment emphasizes the finality of appellate orders and restricts the scope for revision by tax authorities, thereby providing taxpayers with certainty and stability regarding their tax liabilities.