2001 (9) TMI 32

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....9-80, 1980-81 and 1981-82. The assessee's grievance, which resulted in the reference is regarding the revision of the assessment order, which had been passed on January 25, 1983. The revisional order had been passed on March 25, 1985. The assessee contends that the revisional order is one, which should not have been made having regard to the circular, which the Central Board of Direct Taxes had is....

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.... within two years of the date of the order sought to be revised in cases where the order sought to be revised was passed before 1st October, 1984." The learned senior standing counsel for the Department has informed us that the Department has consistently followed the circular. No reason has been stated as to why that circular was disregarded in the instant case. The assessee herein is as much en....