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    <title>2021 (12) TMI 1256 - ITAT MUMBAI</title>
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    <description>The Tribunal held that the order passed by the Commissioner of Income Tax (Exemptions) under section 263 was barred by limitation as the show-cause notice was issued beyond the prescribed period. The reassessment proceedings initiated under section 147 were deemed valid. The consultancy fee received by the assessee was considered as business income, and the reassessment order was upheld. Consequently, the Tribunal quashed the revision order, rendering other grounds raised by the assessee infructuous. The appeal was allowed, and the order was pronounced on 23/12/2021.</description>
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      <title>2021 (12) TMI 1256 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=416490</link>
      <description>The Tribunal held that the order passed by the Commissioner of Income Tax (Exemptions) under section 263 was barred by limitation as the show-cause notice was issued beyond the prescribed period. The reassessment proceedings initiated under section 147 were deemed valid. The consultancy fee received by the assessee was considered as business income, and the reassessment order was upheld. Consequently, the Tribunal quashed the revision order, rendering other grounds raised by the assessee infructuous. The appeal was allowed, and the order was pronounced on 23/12/2021.</description>
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