Limitation for rectification applications runs from the original relief order, not from later rectification orders.

Limitation for a rectification application under section 154 of the Income-tax Act, 1961, was held to run from the earlier orders granting relief under section 49A of the Indian Income-tax Act, 1922, and not from the later rectification orders passed under section 154. The later rectification orders did not create a fresh starting point for limitation, so the assessee's subsequent applications were treated as time-barred and rejected.

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Issues: Whether the period of limitation for an application for rectification under section 154 of the Income-tax Act, 1961, had to be computed from the earlier orders granting relief under section 49A of the Indian Income-tax Act, 1922, or from the later rectification orders passed under section 154 of the Income-tax Act, 1961.

Analysis: The assessment years were 1954-55 and 1955-56. For both years, the Income-tax Officer had first passed orders granting relief under section 49A, and later passed rectification orders under section 154. The assessee's subsequent applications for rectification were rejected as time-barred. The Court held that the relevant point for computing limitation was the earlier order in each assessment year, because the later rectification order did not furnish a fresh starting point for limitation.

Conclusion: The limitation period ran from the earlier orders and not from the subsequent rectification orders; the question was answered in the affirmative and against the assessee.

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