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2012 (6) TMI 518 - AT - Income TaxAdmissibility of petition for revision of order of Tribunal beyond period of 4 years from date of the order - appeal filed on 04.04.2012 against ex-parte order dated 23.02.07 rendered in respect of AY 97-98 - assessee contending limitation of period from date of service of order - Held that:- U/s 254(2), the Statute has chosen not to compute the period of limitation from the date when an ITAT order is served, but the Statute has chosen to compute the time within four years from the date of the order. Although another four years has further been granted for filing a petition u/s.254(2) by the Statute, but on assessee having reasonable cause for non-filing of appeal. In present case, appeals filed in 2003, remained pending, until decided on 23/02/2007 ex-parte. Appellant has never enquired in the said four years between 2003 to 2007 about the fate of his appeals. After the lapse of 8 years, undisputedly a long gap, now this assessee is seeking a favourable decision which may tantamount to re-writing the Statute. Therefore, condonation as sought through these petitions is beyond jurisdiction, hence rejected.
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