Incorrect assessee name and rectification extended limitation period, preserving the right of appeal and defeating a technical time-bar.

Assessment orders issued in an incorrect name were later rectified on the assessee's application, and the appeal period was treated as running from service of the amended orders. The appeals were therefore held to be within time. Even if any delay were assumed, the confusion caused by the description of the assessee and the rectification process constituted sufficient cause for condonation. A mere technical error in naming the assessee could not defeat the right of appeal, and the order rejecting the appeals as time-barred was set aside.

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Issues: Whether the assessee's appeals were barred by limitation after rectification of the assessment orders to correct the name of the assessee, and whether delay, if any, deserved condonation.

Analysis: The assessment orders were originally issued in an incorrect name and were later rectified on the assessee's application. The appeal period was treated as running from service of the amended orders. On that basis, the appeals were filed within time. Even otherwise, the confusion created by the incorrect description of the assessee and the rectification proceedings constituted sufficient cause for any assumed delay. A mere technical mistake in the name of the assessee could not defeat the right of appeal.

Conclusion: The appeals were within time and were not liable to be dismissed as barred by limitation. The order rejecting the appeals on limitation was set aside, in favour of the assessee.

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