Timely rectification representations remain maintainable where administrative inaction caused delay, requiring fresh consideration under law.

Timely rectification representations cannot be rejected as time-barred merely because the tax authority failed to dispose of them within the stipulated period. Where representations were submitted within time and remained pending, the authority cannot rely on its own inaction to deny consideration on limitation grounds. The stated conclusion is that the time-bar rejection was unsustainable and that the rectification representations must be reconsidered afresh in accordance with law.

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Issues: Whether the rectification representations could be rejected as time-barred when they had been made within time but remained undisposed of by the tax authorities.

Analysis: The representations were received in 2020 and again in 2023, but the authority did not dispose of them within the stipulated period. An authority cannot rely on its own failure to act upon a timely application to non-suit the applicant on limitation.

Conclusion: The time-bar rejection was unsustainable; the rectification representations must be considered afresh in accordance with law.

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