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2006 (8) TMI 613 - ITAT ALLAHABAD
Extract:
....... as the order under section 263 has not been found to be maintainable on any of the three grounds which the ld. CIT has finally picked up for decision against the assessee, the only consequence that follows is that the order under appeal is liable to be declared as wholly without jurisdiction and I hold so. 33. In the result, the appeal is allowed.