Rectification Request u/s 254(2) Denied as Time-Barred; Filed After Six-Month Limitation Period Expired.

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....Rectification of mistake u/s 254 - period of limitation - keeping in view factual matrix of the instant case, the MA ought to have been filed by assessee latest by 30.11.2016 viz. six months from the date new amended provision came into effect, as on the date of amendment on 01.06.2016, in the instant case, the unexpired limitation period under the old law was more than six month. The assessee has filed this MA on 20.01.2017 which is clearly time barred keeping in view amended provisions of Section 254(2), and hence this MA is not maintainable. - AT....