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1973 (9) TMI 15 - KERALA HIGH COURT“(i) Whether the order of penalty passed by the ITO dated March 19, 1969, in pursuance of the directions contained in the order of the ITAT in I. T. A. No. 9202 of 1966-67, dated December 7, 1968, is time-barred ? (ii) Whether the assessee is estopped from contending that the order of penalty passed by ITO in pursuance of the directions contained in the order of the Income-tax Appellate Tribunal in I. T. A. No. 9202 of 1966-67, dated December 7, 1968, is illegal and void by not challenging the said decision of the Tribunal by applying for a reference therefrom under section 256(1) of the Income-tax Act, 1961? (iii) Whether the acceptance of the assessee's contention by ITAT and the grant of relief on that basis would not amount to a review of its earlier order and whether the Appellate Tribunal is competent to review its previous order?” - Section 275 of the Income-Tax Act, 1961 does not permit any relaxation of the rigidity of the rule of limitation, it is specifically mentioned in section 153(3) and 263(3) that period of limitation will not apply when the authority acts under the direction of appellate authority
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