Longer limitation means a substantive right which cannot be curtailed by amendment- amendment reducing limitation to file petitions or appeals should be considered prospective only https://www.taxtmi.com/article/detailed?id=7608 Section 254(2) distinguishes Tribunal suo moto rectification-subject to a reduced procedural window-from mandatory rectification on application by the assessee or Assessing Officer; there is no express filing time limit for party-initiated rectification and the Tribunal must amend when a mistake apparent from the record is brought to its notice, with the reduced suo moto timeframe applying prospectively rather than retroactively. en-us Tue, 12 Sep 2017 07:33:51 +0530 Tue, 12 Sep 2017 07:33:51 +0530 TaxTMI RSS Generator Longer limitation means a substantive right which cannot be curtailed by amendment- amendment reducing limitation to file petitions or appeals should be considered prospective only https://www.taxtmi.com/article/detailed?id=7608 Section 254(2) distinguishes Tribunal suo moto rectification-subject to a reduced procedural window-from mandatory rectification on application by the assessee or Assessing Officer; there is no express filing time limit for party-initiated rectification and the Tribunal must amend when a mistake apparent from the record is brought to its notice, with the reduced suo moto timeframe applying prospectively rather than retroactively. Articles Income Tax Tue, 12 Sep 2017 07:33:51 +0530 https://www.taxtmi.com/article/detailed?id=7608