Four-year rectification limit applies equally to Tribunal action and party applications under the income-tax statute.

Section 254(2) imposes a four-year limit on both suo motu rectification by the Tribunal and rectification sought by the assessee or the Assessing Officer. The provision was treated as containing one rectification power with the same temporal restriction for each mode of invocation, because the statutory phrase "at any time within four years from the date of the order" governs the entire section. The text was read as clear and unambiguous, and comparative statutory references confirmed that different limitation structures are used expressly when intended. Strict construction of fiscal provisions and the finality of limitation periods support the bar on rectification after expiry of four years.

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Issues: Whether the four-year limitation in section 254(2) of the Income-tax Act, 1961 applies both to rectification made by the Tribunal on its own motion and to rectification made on an application by the assessee or the Assessing Officer.

Analysis: The provision was read as containing two forms of the same rectification power: discretionary rectification by the Tribunal and mandatory rectification when a mistake is brought to its notice by a party. The limiting words "at any time within four years from the date of the order" were held to govern both forms of action because the amendment contemplated by the section is the same in each case. The text was treated as clear and unambiguous, leaving no scope to infer an unlimited period for party-initiated applications. The comparative references to earlier and other statutory provisions were used to reinforce that where the legislature intended a different limitation structure, it said so expressly. Principles of strict construction of fiscal statutes and finality of limitation periods were applied to reject any equitable extension beyond the statutory period.

Conclusion: The four-year limitation applies equally to suo motu rectification and to rectification on application by a party; rectification after expiry of four years is barred.

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