2002 (7) TMI 102

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...., on a miscellaneous application under section 254(2) of the Income tax Act, 1961. The appellant is a public limited company duly incorporated under the provisions of the Companies Act, 1956. The relevant assessment year is 1990 91. On May 31, 1995, the Tribunal has decided the appeal in I. T. A. No. 1122/ JP of 1994. Thereafter, the miscellaneous application has been moved for rectification of t....

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...., and the assessee has moved the miscellaneous application on December 15, 1998, before the Tribunal, i.e., within four years, though the order has been passed on miscellaneous application on December 24, 1999. It is true that in the language the words used are that the Appellate Tribunal may at any time within four years from the date of the order rectify the mistake apparent from the record but ....