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2011 (6) TMI 12 - HC - Income TaxRevision of orders - Once the taxability under the seized documents have been considered by CIT(A), the CIT u/s 263 of the Act cannot seek to consider the taxability under the very same documents once again - The Tribunal has recorded the fact that the two documents cannot be read independent of each other - The Tribunal has recorded a fact that once the taxability under both the documents have been considered by the assessing officer and also by the CIT(A), it is not open to the CIT to invoke the jurisdiction u/s 263 of the Act and direct the assessing officer to consider the taxability under those two documents once again - Hence,no fault can be found with the decision of the Tribunal in setting aside the order of CIT under Section 263 of the Act.
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