Limitation Period for Rectification u/s 254 Starts When Assessee Learns of Order, Not Issuance Date.

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....Rectification of mistake u/s 254 - Period of limitation would begin to run from the date the assessee got knowledge of the order or from the date of passing of the order - The period of limitation would thus commence only from 19.11.2019 which is the date of obtaining knowledge of the order dated 01.02.2013. The period spent by the assessee after it got knowledge of the dismissal of its appeals in limine from November 2019 to March-2020 is the period spent in prosecuting the remedy provided under the said Act. From the aforesaid we are satisfied that the time spent from 19.11.2019 till filing of the present appeals has been sufficiently explained by the applicants. - HC....