The assessee obtained a settlement of all disputes pertaining to tax demands and form 5 was issued and the total liability determined and conferred finality in terms as contemplated under the provisions of the Direct Tax Vivad Se Vishwas Act. Thereafter, the Assessing Officer invoked the power conferred by section 154 of the 1961 Act to revisit the computation of liability which had stood settled, up to the stage of appeal before the Commissioner (Appeals). On a writ   allowing the petition the Court held  that the validity of notice for rectification had to be evaluated on the basis of the date of its issuance as opposed to when the same may have been drawn. The reasons for rectification under section 154 of the 1961 Act, stated that the Assessing Officer while computing the additions in the original order of assessment, dated December 22, 2017, had referred to and applied an incorrect tax rate. The Commissioner (Appeals), while according part relief had recomputed the taxable income of the assessee and even at that stage, the issue of a wrong tax rate having been applied had not been either raised or alluded to. Even assuming that the power under section 154 of the 1961 Act was available to be exercised, notwithstanding the conclusion of proceedings under the Direct Tax Vivad Se Vishwas Act and the issuance of form 5, it would not be sustainable since the statutory period of limitation which would apply. That the rectification order, which was asserted to be passed in exercise of the powers conferred under section 154 of the 1961 Act, would not fall within the ambit of section 154 of the Direct Tax Vivad Se Vishwas Act. It was not the case of the Revenue that the assessee had failed to make a disclosure with respect to any material particular or any disclosure so made subsequently being found to be false. The rectification notice, rectification order under section 154 of the 1961 Act, the notices and order of demand under section 156 of the 1961 Act were quashed. The assessee and the Revenue should proceed in terms of the determination of tax made under the Direct Tax Vivad Se Vishwas Act ( AY. 2015-16)