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    <title>2022 (11) TMI 307 - ITAT MUMBAI</title>
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    <description>The Tribunal held that the order passed under section 154 of the Income Tax Act was beyond the limitation period, rendering it non-est due to a significant delay in reviving the proceedings by the Assessing Officer. Additionally, the Tribunal found that the rectifications made by the Assessing Officer on the depreciation claim for a plant and TDS deduction were on debatable issues, as the eligibility of the plant for higher depreciation and the TDS deduction were subject to interpretation and evidence. Consequently, the Tribunal upheld the Commissioner of Income Tax (Appeals)&#039;s order, dismissing the Revenue&#039;s appeal for lack of merit.</description>
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      <title>2022 (11) TMI 307 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=429883</link>
      <description>The Tribunal held that the order passed under section 154 of the Income Tax Act was beyond the limitation period, rendering it non-est due to a significant delay in reviving the proceedings by the Assessing Officer. Additionally, the Tribunal found that the rectifications made by the Assessing Officer on the depreciation claim for a plant and TDS deduction were on debatable issues, as the eligibility of the plant for higher depreciation and the TDS deduction were subject to interpretation and evidence. Consequently, the Tribunal upheld the Commissioner of Income Tax (Appeals)&#039;s order, dismissing the Revenue&#039;s appeal for lack of merit.</description>
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