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    <description>Revisional power under section 39(2) applies only where the order is both erroneous and prejudicial to Revenue; a merely prejudicial order is insufficient, so revision failed. Reassessment under section 19A had to be initiated within three years from the relevant declaration of law, and the limitation period did not restart from a later consequential order. Since the taxability of coal ash had already been declared earlier, the reassessment initiated later was time-barred. Revision could not be used indirectly to revive a barred assessment issue by challenging the order closing reassessment proceedings, so the revisional order was unsustainable.</description>
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      <description>Revisional power under section 39(2) applies only where the order is both erroneous and prejudicial to Revenue; a merely prejudicial order is insufficient, so revision failed. Reassessment under section 19A had to be initiated within three years from the relevant declaration of law, and the limitation period did not restart from a later consequential order. Since the taxability of coal ash had already been declared earlier, the reassessment initiated later was time-barred. Revision could not be used indirectly to revive a barred assessment issue by challenging the order closing reassessment proceedings, so the revisional order was unsustainable.</description>
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