Upholds AO’s inherent power to suo-moto rectify mistakes in assessment orders. But strikes down rectification order u/s 154 which in fact was a reassessment order.

Upholds AO’s inherent power to suo-moto rectify mistakes in assessment orders; Interprets Section 21 of the General Clauses Act; However, strikes down rectification order u/s 154 which in fact was a reassessment order; Confirms ITAT ruling : Uttarakhand HC in Karjat Trade Place Pvt. Ltd. karjat trade place