PCIT vs Income tax Appellate Tribunal

Whether the Income Tax Appellate Tribunal's order recalling an ex-parte dismissal and restoring an appeal for fresh hearing, passed beyond the six-month limitation period prescribed under Section 254(2) of the Income Tax Act, is valid --- Held Yes. The limitation period under Section 254(2) applies to the filing of the rectification application by the assessee, not to the Tribunal's disposal. The Tribunal retains inherent power for procedural review under Rule 24 of the Income Tax (Appellate Tribunal) Rules, 1963, to ensure natural justice.