Limitation Period for second rectification should reckon from original order date

Karnataka Power Corporation Limited Vs ACIT (ITAT Bangalore)

Hon’ble jurisdictional High Court in the case of M/s. Kothari Industrial Corporation Limited v. The Agricultural Income Tax Officer reported in 230 ITR 306 had held that the period of limitation for a second rectification should be reckoned from the date of original order, if subject matter of second rectification is different from subject matter of the first rectification. The relevant finding of the Hon’ble jurisdictional High Court reads as follow:-

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