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    <title>2022 (2) TMI 1463 - DELHI HIGH COURT</title>
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    <description>Time spent prosecuting an appeal under a bona fide but mistaken belief that the order was appealable was excludable under section 14 of the Limitation Act, 1963 when the proceeding was pursued before a forum lacking jurisdiction. On that basis, the delay in filing the revision petition under section 264 of the Income-tax Act, 1961 was to be computed after excluding the period spent in the earlier appeal. The revision petition was therefore within limitation and could not be rejected as time-barred; it had to be considered on merits.</description>
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      <description>Time spent prosecuting an appeal under a bona fide but mistaken belief that the order was appealable was excludable under section 14 of the Limitation Act, 1963 when the proceeding was pursued before a forum lacking jurisdiction. On that basis, the delay in filing the revision petition under section 264 of the Income-tax Act, 1961 was to be computed after excluding the period spent in the earlier appeal. The revision petition was therefore within limitation and could not be rejected as time-barred; it had to be considered on merits.</description>
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