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HC held that the assessee's rectification application under s. 254(2) was within limitation, as the limitation period commences from the date of service of the order sought to be rectified, read harmoniously with the relevant Tribunal Rules requiring copies of the order to accompany such application. Since the order was served only on 24 March 2025 and the miscellaneous application was filed within six months thereof, ITAT erred in treating it as time-barred and in relying on the Leena Power Tech decision, which was distinguishable. The writ petition was disposed of by clarifying that all grounds on merits remain open to be urged in the pending appeal against the original order.
HC held that the assessee's rectification application under s. 254(2) was within limitation, as the limitation period commences from the date of service of the order sought to be rectified, read harmoniously with the relevant Tribunal Rules requiring copies of the order to accompany such application. Since the order was served only on 24 March 2025 and the miscellaneous application was filed within six months thereof, ITAT erred in treating it as time-barred and in relying on the Leena Power Tech decision, which was distinguishable. The writ petition was disposed of by clarifying that all grounds on merits remain open to be urged in the pending appeal against the original order.
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