Rectification limitation is counted from the original assessment order, making belated notices time-barred and consequential orders invalid.

Rectification limitation runs from the date of the original assessment order, and a prior rectification does not extend that period in ordinary cases because the statute creates no fiction restarting limitation, unlike the specific rule for firm-related rectifications. On the facts, the notice relating to the 1961-62 assessment was issued after four years from the original assessment order and was therefore time-barred and without jurisdiction. The later notices for subsequent years were merely consequential on the first notice and could not survive once the initial notice was invalid. The consequential rectification orders accordingly could not stand.

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Issues: Whether the notices issued for rectification were barred by limitation and, consequently, without jurisdiction.

Analysis: The limitation for rectification under the governing provision ran from the date of the original assessment order, and a prior rectification did not enlarge that period. The statute did not create any fiction that a rectified order would restart limitation in ordinary rectification cases, unlike the specific language used for firm-related rectifications. On the facts, the impugned notice in relation to the 1961-62 assessment was issued beyond four years from the original assessment order. The later notices for the subsequent years were only consequential and depended upon the validity of the first notice.

Conclusion: The rectification notices were time-barred and beyond jurisdiction, and the consequential rectification orders also could not stand.

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