Rectification applications under section 254(2) must comply with the six-month limit, or they are time barred.

Rectification applications under section 254(2) of the Income-tax Act were held to be time barred where filed beyond the prescribed six-month limitation period. The Tribunal noted a delay of 319 days and held that it had no power to entertain applications filed after the statutory time limit. The miscellaneous applications were therefore dismissed.

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Issues: Whether the miscellaneous applications filed for rectification were barred by limitation under section 254(2) of the Income-tax Act, 1961.

Analysis: The applications were filed with a delay of 319 days. The applicable limitation under section 254(2) permits rectification only within the prescribed six-month period, and the Tribunal held that it had no power to entertain applications filed beyond that time limit.

Conclusion: The miscellaneous applications were time barred and were dismissed.

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