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    <title>2023 (5) TMI 1290 - CALCUTTA HIGH COURT</title>
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    <description>The HC dismissed the revenue&#039;s appeal under Section 260A of the Income Tax Act, 1961, against the ITAT, Kolkata&#039;s order for the 2015-16 assessment year. The Tribunal determined that the PCIT&#039;s invocation of Section 263 was time-barred and unjustified, as it did not stem from the rectification order under Section 154. Additionally, the Tribunal found that Section 115QA was inapplicable to the assessee due to specific provisions of the Companies Act regarding buy-backs. The Tribunal concluded there were no substantial questions of law, leading to the dismissal of the revenue&#039;s appeal.</description>
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      <description>The HC dismissed the revenue&#039;s appeal under Section 260A of the Income Tax Act, 1961, against the ITAT, Kolkata&#039;s order for the 2015-16 assessment year. The Tribunal determined that the PCIT&#039;s invocation of Section 263 was time-barred and unjustified, as it did not stem from the rectification order under Section 154. Additionally, the Tribunal found that Section 115QA was inapplicable to the assessee due to specific provisions of the Companies Act regarding buy-backs. The Tribunal concluded there were no substantial questions of law, leading to the dismissal of the revenue&#039;s appeal.</description>
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