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2022 (2) TMI 1273 - AT - Income TaxRectification u/s 154 - non-consideration of decision of Jurisdictional High Court - Whether effect of provision of section 234E of the Act is not retrospective and the same is prospective? - HELD THAT:- We find that on careful perusal of our order is contrary to the decision is contrary to the finding of jurisdictional High Court as, we have missed the material finding of Hon'ble High Court. Considering the fact that decision [2021 (7) TMI 1373 - ITAT SURAT] is in conflict with the order of Hon'ble Jurisdictional High Court, therefore, this is a mistake apparent on record. Therefore, the consolidated order is recalled. Considering the fact that we have recalled the order, the hearing of all the appeals is fixed on 30.05.2022, for hearing all the appeals afresh on merit. Parties be informed accordingly, copy of this order be kept in all files - All the MA’s filed by revenue are allowed.
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