If once recovery following reassessment is made ,can after 6 years , other ITO charge interest mentioning that less interest was calculated by previous ITO?Is there no limitation period?
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Regarding recovery made by ITO
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Yes the successor ITO can pass rectification order after giving an opportunity to be heard if he finds that the interest has been under charged in the original assessment order. however limitations are there. the rectification order has to be passed within 4 years from the end of the relevant financial year during which the original order had been passed
In this case under section 226(3),recovery was made with interest on delayed payment .Does limitation of 4 year apply in this case too,apart from common assessment orders ?
@ Ramakrishnan Sir and other experts,pls throw some light as it is commonsense that none can keep looking into errors of self to create demand from anyone.
The difference in interest computation might be pointed out by audit party
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