ITAT Kolkata Rejects Revenue's Time-Barred Rectification Petition Under Section 254(2)

Overview of the Judicial Pronouncement

In a recent judicial determination, the Income Tax Appellate Tribunal (ITAT), Kolkata bench, delivered a crucial ruling regarding the strict enforcement of statutory timelines for filing rectification applications. The matter, adjudicated in the case of DCIT Vs Shibdas Sen, highlights the rigid nature of the limitation period prescribed under `Section 254(2)` of the `Income-tax Act, 1961`. The Tribunal dismissed the Miscellaneous Application (MA) presented by the Revenue, citing that the plea was instituted well past the permissible six-month window.