2023 (11) TMI 1354

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..... eous Application u/s. 254(2) - HELD THAT:- The sub-section (2) of section 254 mandates that the Tribunal at any time within six months from the end of the month in which the order was passed can rectify any mistake apparent from the record, if the mistake is brought to its notice by the assessee or Assessing Officer. Tribunal order dated 21/09/2021 was dispatched to the assessee through Registere .....

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..... 22 i.e. after almost three months of expiry of limitation. Tribunal has no jurisdiction to condone delay in filing of Miscellaneous Application u/s. 254(2) of the Act. [Re. Karuturi Global Ltd. [2019 (7) TMI 939 - KARNATAKA HIGH COURT]].
SHRI B.R. BASKARAN , ACCOUNTANT MEMBER AND SHRI VIKAS AWASTHY, JUDICIAL MEMBER For the Applicant : Shri Devendra Jain For the Respondent : Shri Ashok Kumar .....

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..... e on record. The Hon'ble Bombay High Court in the case of Daryapur Shetkari Sahakari Ginning and Pressing Factory vs. ACIT, 123 taxmann.com 301(Bom) has held that the period of limitation prescribed in section 254(2) of the Act would commence from the date when the order comes to the knowledge of affected party. In the present case, if limitation for filing of Miscellaneous Application is calc .....

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