810/CBDT.

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....Audit objection was raised the Commissioner could have taken action to rectify the mistake under section 263 within two years of the assessment but he could not do so as in the meanwhile the Appellate Assistant Commissioner had decided an appeal. According to the Ministry the legal position based on a Supreme Court decision in 1958 is that the Commissioner cannot exercise the power under section 2....

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....unts Committee has been examined in consultation with the Ministry of law, Justice and Company Affairs. On a careful consideration of certain pronouncements made by the Supreme Court and some of the High Courts on the doctrine of merger, the Ministry of law are of the considered view that points which have been dealt with in the order of the Income-tax Officer but have not been covered by the orde....