https://www.taxtmi.com/caselaws?id=191228 A memorandum of appeal rejected at the threshold, before admission and fixation of hearing, is treated as an order under section 30(2) of the Income-tax Act, 1922, not under section 31. Rectification under section 35(4) creates a fresh notice of demand under section 29 only when it enhances the assessment or reduces a refund. Where rectification is favourable to the assessee and merely reduces the demand, no fresh notice of demand arises and no fresh limitation period for appeal begins. On that basis, the original demand remained the relevant starting point for limitation. en-us Wed, 11 Oct 1950 00:00:00 +0530 Sat, 25 Mar 2017 12:23:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191228 A memorandum of appeal rejected at the threshold, before admission and fixation of hearing, is treated as an order under section 30(2) of the Income-tax Act, 1922, not under section 31. Rectification under section 35(4) creates a fresh notice of demand under section 29 only when it enhances the assessment or reduces a refund. Where rectification is favourable to the assessee and merely reduces the demand, no fresh notice of demand arises and no fresh limitation period for appeal begins. On that basis, the original demand remained the relevant starting point for limitation. Case-Laws Income Tax Wed, 11 Oct 1950 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191228