Held that for workability of scheme of section 254(2) limitation period is to be counted from date of service of order and not from date of order. On fact that there was no evidence of service of order and that there was no reason to dispute or doubt statement made by assessee including on affidavit, MA deserved to be decided on merits. (AY. 2005-06)
Techknoweledgy Interactive Partners P. Ltd. (2021) 190 ITD 643 / 205 DTR 1 / 213 TTJ 1 (Mum.)(Trib.)
S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Limitation period is to be counted from date of service of order and not from date of order.