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2022 (5) TMI 1601
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....jit Kumar (JCIT) - Ld. Sr. DR For the Respondent : None ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. By way of this Miscellaneous Petition, the Revenue seeks recall of Tribunal order passed in ITA No.3039/Chny/2018 on 23.12.2020. The bench, in para-4 of the order, quashed the order passed by Ld. AO on 26.02.2016 which is consequent to revisional order u/s 263. This was by consider....
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....ought by the revenue by way of petition which is on record. It has been submitted as under: - It is humbly submitted that the Hon'ble ITAT, A Bench, Chennai has dismissed the appeal of the Department / Revenue vide order in ITA No, 3039/CHNY/2018 dated 23/12/2020. The Order has been received by the office of the CIT (Judicial), Chennai on 06/01/2021 and it was received by the....
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....that the filing of Misc Application has been approved and directed to do the necessary action in this regard. It is humbly stated that the limitation for rectification of any mistake u/s 254(2) of the IT Act, 1961 in this case was on 30/06/2021. But there is a delay in filing the Misc Application of 55 days, It is humbly stated that the delay is totally unintentional and due to the Lockdo....
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....itted that the Tribunal has erred in considering the amended provisions of Sec.153(3) since the new time-line has come into force only w.e.f. 01.06.2016 by Finance Act, 2016. It has been submitted that the order u/s 263 was passed on 19.12.2014. As per the old provisions of 153(2A), the time limit to pass such an order was one year from the end of the financial year in which the order was received....