2019 (11) TMI 936
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....r Standing Counsel ORDER This writ petition is filed challenging the communication dated 12.06.2018 issued by the first respondent informing the petitioner that Revision Application filed under Section 264 of the Income Tax Act, 1961 for the Assessment Years 2000-01 to 2012-13 was already disposed of as "Void ab initio" on 03.03.2016, since the said application was filed more than a year after t....
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....his stage, is not expressing any view on the merits of such dispute raised by the petitioner under Section 264, for the simple reason that the first respondent has chosen to reject the said revision petition only on the ground of limitation. However, it is not in dispute that the decision taken by the first respondent on 03.03.2016 to reject the revision as time barred, has not been communicated t....
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....t no such decision is taken in the eye of law. However, as it is communicated through the impugned proceedings dated 12.06.2018 that the Revision Application filed by the petitioner was already rejected on 03.03.2016, this Court is of the view that it is better for the first respondent to consider the matter afresh including the question of limitation by giving an opportunity of hearing to the pet....