https://www.taxtmi.com/caselaws?id=56233 Section 254(2) imposes a four-year limit on both suo motu rectification by the Tribunal and rectification sought by the assessee or the Assessing Officer. The provision was treated as containing one rectification power with the same temporal restriction for each mode of invocation, because the statutory phrase "at any time within four years from the date of the order" governs the entire section. The text was read as clear and unambiguous, and comparative statutory references confirmed that different limitation structures are used expressly when intended. Strict construction of fiscal provisions and the finality of limitation periods support the bar on rectification after expiry of four years. en-us Wed, 26 May 2004 00:00:00 +0530 Mon, 17 Jun 2024 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56233 Section 254(2) imposes a four-year limit on both suo motu rectification by the Tribunal and rectification sought by the assessee or the Assessing Officer. The provision was treated as containing one rectification power with the same temporal restriction for each mode of invocation, because the statutory phrase "at any time within four years from the date of the order" governs the entire section. The text was read as clear and unambiguous, and comparative statutory references confirmed that different limitation structures are used expressly when intended. Strict construction of fiscal provisions and the finality of limitation periods support the bar on rectification after expiry of four years. Case-Laws Income Tax Wed, 26 May 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56233