1998 (9) TMI 13

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....mission to change the previous year in exercise of the powers conferred on him under section 263 of the Income-tax Act, 1961, has once again after an interval of three years, made that very permission granted earlier the ground for interfering with the order of the Income-tax Officer who had merely given effect to the permission which the Commissioner himself has granted earlier on March 11, 1988,....

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....In the notice issued on March 6, 1991, it is stated in the opening paragraph "as a result of the permission granted for the change in previous year the assessment for 1986-87 has been skipped and there is loss of revenue. The above order is, therefore, considered as erroneous and prejudicial to the interests of the Revenue." This is clearly an instance of bolting the barn after the horse had ru....