This demonstrates the inadvisability of relying on ersatz interpretations of JAR-FCL, such as LASORS. The real requirement is:
A pass in the theoretical knowledge examinations given in accordance with JAR–FCL 1.490 will be accepted for the grant of the CPL(A) or IR(A) during the 36 months from the date of gaining a Pass in all the required examination papers.
So, provided that the application is received by the issuing Authority within 36 months of the last exam pass, the IR should be issued.