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2000 (2) TMI 54

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....surfaced in this petition under article 226 of the Constitution of India is as to whether the impugned order of respondent No. 1, under section 264 of the Income-tax Act, 1961 (the "I. T. Act"), dated March 26, 1992, in respect of the assessment years 1975-76 to 1981-82 (7 years), whereby the revision application of the petitioner-assessee came to be rejected on the ground that it was barred by li....

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....on, confirmed it. Prompted by this, the petitioner-assessee filed revision application on January 20, 1984, before the respondent for the assessment years 1975-76 to 1981-82, against the orders under section 143(3) passed by the Income-tax Officer, claiming the part of the incentive bonus as permissible expenditure, Since there was a delay, as the revision was for the past seven years' assessment....

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....en by the Life Insurance Corporation. According to him, each assessment year is separate and independent proceedings and each claim has to be taken up. within the appropriate time frame. He, therefore, held that the assessee was not prevented from making a revision application within the stipulated period, and, therefore, the revision came to be dismissed on the technical ground of barred by limit....