2023 (11) TMI 1354

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....ain For the Respondent : Shri Ashok Kumar Ambastha ORDER PER VIKAS AWASTHY, JM: This Miscellaneous Application has been filed by the assessee u/s. 254(2) of the Income Tax Act, 1961 [in short 'the Act'], seeking rectification/recalling of the Tribunal order dated 21/09/2021. 2. At the outset it is observed that the Miscellaneous Application is time barred. The sub-section (2) of section 254 o....

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....filing of Miscellaneous Application is calculated as per the aforesaid decision of Hon'ble Jurisdictional High Court, the period of six months commence from 17/11/2021 i.e. when the order was received by the assessee. Accordingly, the limitation for filing of appeal expired by the end of May, 2022. The present Miscellaneous Application has been filed on 26/08/2022 i.e. after almost three months of....