Miscellaneous application u/s 254(2) is valid if filed within Four Years of date of actual receipt of judgment

Kamal Nayan Singh Vs DCIT (Jharkhand High Court) Once it is found that the rectification application u/s 254(2) of the I. T. Act, 1961 has been submitted within a period of four years from the date of actual receipt of the judgment and order passed by the tribunal, which is sought to be reviewed, petitioner is entitled to relief. In the case of Sree Ayyanar Spinning & Weaving Mills Ltd. v. Commissioner of Income-tax reported in (2008) 17 SCC 203 the Hon’ble Supreme Court has an occasion to interpret section 254(2) of the I.T. Act, 1961, wherein the fact in short was that miscellaneous ap...