Where a taxpayer had diligently pursued rectification within...

Where a taxpayer had diligently pursued rectification within time and filed the statutory challenge within three months of its rejection, the HC held that limitation could not be computed only from the original assessment order. The appellate authority should not have rejected the challenge as time-barred in those circumstances, and if the absence of a specific challenge to the rectification rejection was treated as a defect, amendment ought to have been permitted instead of dismissal on a hyper-technical ground. The limitation-based rejection was set aside and the matter remitted for fresh decision on merits.