This appeal by department and cross-objection by assessee relate to assessment year 1967-68. first assessment in case was set aside by AAC and fresh assessment was made on 31-7-1973. controversy in present appeal relates to two rectification orders passed with regard to assessment order made on 31-7-1973, which may conveniently be referred to as original assessment. 2. assessee owned three tractors. With regard to two tractors, assessee had paid interest during relevant accounting period. In original assessment, depreciation was allowed only on written down value of tractors. interest paid was not capitalised and added to WDV and, consequently, no depreciation was allowed on this amount. On 4-3-1976, assessee applied for rectification of certain mistakes in original assessment, order. rectification order was passed by ITO under section 154 of Income-tax Act, 1961 (' Act ') on 17-3-1976, wherein ITO added interest paid on balance of unpaid purchase price to WDV and allowed depreciation at 25 per cent on total amount. interest so added to WDV came to Rs. 19,632. He made this addition in case of all three tractors and allowed depreciation accordingly. Subsequently, on 22-11-1978, ITO passed another rectification order, which may conveniently be referred to as second rectification order. As already stated, by first rectification order, ITO had added as interest amount of Rs. 19,632 to WDV of three tractors. Even according to ledger maintained by assessee, there has been no payment of any interest with regard to third tractor bearing No. 619C No. II. There has been such payment of interest only with regard to other two tractors. ITO had, therefore, committed error in adding interest amount of Rs. 19,632 to WDV in case of third tractor in first rectification order. This is clearly mistake apparent from records. It was to correct this mistake that ITO passed second rectification order. By same, he reduced WDV of third tractor by amount of interest, which had been wrongly added to same. Thus, by second rectification order, ITO did not withdraw any relief given by original assessment order. He only corrected mistake committed in first rectification order, which of course, will have effect of reducing relief granted by first rectification order. 3. assessee filed appeal against second rectification order. He raised two contentions. One was that order is barred by limitation, as order has been passed beyond four years of original assessment. second was that issue covered by second rectification order was debatable one and that mistake was not apparent from records. first contention was rejected by Commissioner (Appeals), as second rectification was within four years of first rectification order. Commissioner (Appeals), however, accepted second contention and cancelled second rectification order. 4. In its appeal, department questions correctness of finding of Commissioner (Appeals) that issue involved in second rectification order was debatable one and that mistake corrected was not one apparent from records. facts leading to passing of rectification order have been set out in paragraph No. 2 above. learned counsel for assessee was not able to refute these facts. It is clear from facts stated that adding of interest amount to WDV in case of third tractor, was mistake apparent from records. No debatable issue was involved in correction of this mistake. Commissioner (Appeals) has, therefore, erred in cancelling second rectification order on ground that error was not apparent from records. 5. In cross-objection, assessee questions correctness of finding of Commissioner (Appeals) that second rectification order was not barred by limitation. As already stated, second rectification order was beyond four years of original assessment order but was within four years of first rectification order. 6. Section 154(1)(a) confers powers on ITO to ' amend any order of assessment or of refund or any other order passed by him '. first contention advanced by learned counsel for assessee was that this provision authorises ITO to amend only assessment order or refund order or any other original order and not earlier rectification order. It was claimed that rectification order has no independent existence as by that order, what is done is only to correct assessment order. It was, therefore, claimed that no earlier rectification order was available for further rectification and that what could be rectified is only original assessment order as rectified by earlier rectification order. 7. We are unable to accept this contention. In our view, words ' any other order ' in section 154(1)(a) will include earlier rectification order. rectification order has independent existence. Even appeal has been allowed from order. There may be cases where mistake is only in rectification order and it may not even be reflected in assessment order as corrected by rectification order. We are, therefore, of view that mistake apparent from records in earlier rectification order can be corrected by subsequent rectification order under section 154(1)(a). 8. second contention advanced by learned counsel for assessee was that although mistake occurred in first rectification order, mistake became part and parcel of original assessment order on passing of first rectification order, that any subsequent rectification of mistake will be rectification of mistake in original assessment order and that such rectification is possible only within four years of date of original assessment order. In support of this contention, learned counsel relied upon decision of Gujarat High Court in Ahmedabad Sarangpur Mills Co. Ltd. v. A.S. Manohar, ITO [1976] 102 ITR 712 and that of Calcutta High Court in Bengal Assam Steamship Co. Ltd. v. CIT [1978] 114 ITR 327. On other hand, it was contended by learned departmental representative that mistake was in first rectification order, that same could be corrected within four years of passing of first rectification order and that fact that first rectification order may effect certain changes in original assessment order is totally irrelevant. 9. We have considered matter. In case of Ahmedabad Sarangpur Mills Co. Ltd., mistake sought to be corrected by second rectification order was not one occurring in first rectification order. It was mistake which existed in assessment order even before passing of earlier rectification order. In dealing with this matter, Gujarat High Court observed that: " . . . Even assuming as contended by learned counsel for revenue that limitation should commence to run from first rectification order of May 21, 1965, even then, what was sought to be rectified was mistake which was committed by Income-tax Officer in allowing set off of loss of assessment year 1954-55 against business income of petitioner- company for relevant assessment year 1961-62. In aforesaid first rectification order of May 21,1965, Income-tax Officer had taken same amount, namely, Rs. 12,39,626, as loss for assessment year 1954-55. It, therefore, cannot be said that what was sought to be done by respondent herein was in effect and substance rectification of order of May 21, 1965 . ..." In case of Bengal Assam Steamship Co. Ltd., from facts available i n judgment, it would appear that second rectification was sought with regard to certain mistakes in original assessment orders and that mistakes were not connected with earlier rectification orders. We are inclined to accept contention of learned departmental representative that, in present case, what ITO has rectified is mistake committed in earlier rectification order. We have already held that rectification order has independent existence and that it could be rectified by subsequent rectification order. We are unable to accept contention of learned counsel for assessee that rectification of mistake in earlier rectification order will amount to rectification of mistake in assessment order. If contention of assessee is accepted, ITO will find himself helpless in correcting accidental error or mistake committed in rectification order passed by him on eve of expiry of four years from date of assessment order. This will cause hardship not only to department but to assessee also. We are, therefore, of view that when mistake sought to be rectified is essentially one committed in earlier rectification order, period of limitation for rectifying mistake should be reckoned from date of earlier rectification order and not from date of original assessment order. following commentary of Chaturvedi and Pithisaria's on Income-tax Law, 3rd edition, commentary of Chaturvedi and Pithisaria's on Income-tax Law, 3rd edition, volume 3, lends support to above view: " . . . However, where rectification order itself is to be rectified, period of limitation starts from date of first rectification order and not original order." rectification order under appeal is, therefore, within time. 10. In result, appeal is allowed and cross-objection is dismissed. *** INCOME TAX OFFICER v. NECHUPADOM CONSTRUCTIONS