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    <title>2022 (12) TMI 1002 - ITAT JABALPUR</title>
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    <description>A revision order under section 263 was treated as time-barred because the Revenue failed to prove that it was actually passed on the date it bore. The Tribunal held that the despatch register alone was insufficient, as it did not reliably show when the order left the control of the revisional authority or was handed over for despatch. In the absence of corroborative records explaining the delay, the burden of proving timely passing of the order was not discharged, and the presumption of regularity was not applied. The revision order and the consequential assessment were therefore held invalid under section 263(2).</description>
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    <pubDate>Fri, 09 Dec 2022 00:00:00 +0530</pubDate>
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      <title>2022 (12) TMI 1002 - ITAT JABALPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=431885</link>
      <description>A revision order under section 263 was treated as time-barred because the Revenue failed to prove that it was actually passed on the date it bore. The Tribunal held that the despatch register alone was insufficient, as it did not reliably show when the order left the control of the revisional authority or was handed over for despatch. In the absence of corroborative records explaining the delay, the burden of proving timely passing of the order was not discharged, and the presumption of regularity was not applied. The revision order and the consequential assessment were therefore held invalid under section 263(2).</description>
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      <pubDate>Fri, 09 Dec 2022 00:00:00 +0530</pubDate>
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