https://www.taxtmi.com/caselaws?id=276812 Section 35(5) of the Income-tax Act, introduced as a special rectification provision by legal fiction, was held not to extend the limitation under section 35(1) for assessments already completed before 1 April 1952. The four-year period for rectifying mistakes apparent from the record had to be counted from the original assessment order where section 35(1) applied. Because the relevant assessments were completed on 20 February 1950, the rectification orders made on 27 March 1954 and confirmed on 30 September 1955 were beyond time and without jurisdiction. The orders for the assessment years 1946-47 and 1947-48 were therefore set aside. en-us Wed, 10 Apr 1957 00:00:00 +0530 Sat, 17 Nov 2018 18:07:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276812 Section 35(5) of the Income-tax Act, introduced as a special rectification provision by legal fiction, was held not to extend the limitation under section 35(1) for assessments already completed before 1 April 1952. The four-year period for rectifying mistakes apparent from the record had to be counted from the original assessment order where section 35(1) applied. Because the relevant assessments were completed on 20 February 1950, the rectification orders made on 27 March 1954 and confirmed on 30 September 1955 were beyond time and without jurisdiction. The orders for the assessment years 1946-47 and 1947-48 were therefore set aside. Case-Laws Income Tax Wed, 10 Apr 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276812