s.254(2)- Rectification application can be moved within the period of four years from the date of Tribunal Order

The contention of the learned Sr.AR to the effect that the Revenue moved rectification application in the year 2011 i.e. after around 3 years from the date of passing of the Tribunal order u/s 254(1), belies the Revenue’s stand of such ground having been in fact taken, is without any force. When section 254(2) provides a period of limitation of four years from the date of passing of the order, it implies that any rectification application moved within this statutory period of four years requires consideration. As the instant application u/s.254(2) is well within the stipulated period, in our...